| OCR Text |
Show Nentities, corporate ordinarily and that though to eircumvent fraud the entity may be regarded as a fietion, substantial, 206 G,. &. it must be existence, BOT» ao Ge. regarded Cb, as having a real, Donnell v, Herring-Hall, #88 dey EG, , Se a 4013 Klein v. Bd, of Supervisors, 282 U. S, 19, 51 Ss. Ct. 15, 75 be SG, 140, 73 A. L. BR, 879, Nor does the fact thet one person owns all or substantially all of the stock of the corporation at all changes the rule, Alelio v, Crampton (C, C. A.) 201 F. 891; Ga, Ry. Co. v. Georgia (D, CC.) 289 F, 878: Winfield v. Wichita Natural Gag Co, (C. Cy. A.) B67 F. 47. Particularly is it true as regards taxation and matters of gevarnment fise, that the members of a corporation tially anc the different Com'r corporation entities, (C. C, Ay) 51 F, itself are Darby-Lynde essen- Co, v. (2d) 38; Merr v. U. 5,, 260 U, 5. 566, 45 5. Ct. 575, 69 Fiein v, Bd, of Supervisors, 262 Ly 0. structure system 15, 75 L, Ed, 140, upoh &@ of the recognition with, these absent, the 72 A, Le Re 679, federal of, taxing and distinetions, government an or nis is the &. Ct, based compliance Fraudulent aecepts convenience, The whole exact represents Itself to be, and one Leonlike, change thet appearance sity Hd, 10793 S. 19, $1 pretense taxpayer ss it may not, chameto suit his neces« Especially may he not, as here, for the purpose of obtaining a deduction which he could have had if the matter had taten individual form, deny thet substance to these entitles whieh in the conduct of the business, the aking of the tax returns, and in all other respects he ot all times hes consistently and definitely af-~ rirmed, "Though, then, it is true in District Judge said it was, that the year's work was a benefit a sense as the "tthe result of or a loss toe Chap- assets wnincor~ man, and the tex was, in reality, paid by him, because he owned the companies,' this is not the kind of reality of which he may avail, It is but & remote reality, the result of direct, of immediate realities, the operation of corporations which, though created by him from the of poratec assoclations which he owned, are none the Less in law separate and distinet from each other and from him, with whom, and not with him, the government has dealt and must continue to deal," |