Schenley Distillers Corp. v. United States, 326 U.S. 432 (1946). · Go Syfert
Schenley Distillers Corp. v. United States, 326 U.S. 432 (1946). Cases Citing This Book View Copy Cite
381 citation events (65 in the last 25 years) across 58 distinct courts.
Strongest positive: Farmers & Merchants State Bank v. Direct Scaffold Services Co. (tnmd, 2016-03-17)
Treatment trajectory · 1946 → 2026 · click a year to view as-of
1946 1986 2026
Top citers, strongest first. 43 distinct citers. How cited ↗
examined Cited as authority (quoted) Farmers & Merchants State Bank v. Direct Scaffold Services Co. (3×)
M.D. Tenn. · 2016 · quote attribution · 3 verbatim quotes · confidence low
one who has created a corporate arrangement, chosen as a means of carrying out his business purposes, does not have the choice of disregarding the corporate entity in order to avoid obligations.
examined Cited as authority (quoted) United States v. Golden Acres, Inc. (3×)
D. Del. · 1988 · signal: see, e.g. · quote attribution · 3 verbatim quotes · confidence low
... corporate entities may be disregarded where they are made the implement for avoiding a clear legislative purpose ...
discussed Cited as authority (rule) Arnold v. LME, Inc.
D. Minnesota · 2023 · confidence medium
For example, the Plaintiffs now admit that they were wrong about the Wilsey’s involvement in Finish 5 See Schenley Distillers Corp. v. United States, 326 U.S. 432, 437 (1946) (“While corporate entities may be disregarded where they are made the implement for avoiding a clear legislative purpose, they will not be disregarded where those in control have deliberately adopted the corporate form in order to secure its advantages and where no violence to the legislative purpose is done by treating the corporate entity as a separate legal person.”); Bruhn’s Freezer Meats of Chicago, Inc. v. U…
discussed Cited as authority (rule) USA v. LightRay Captl
5th Cir. · 2021 · confidence medium
Accordingly, shareholders such as LightRay do not have an “ownership interest in the specific property sought to be forfeited” and therefore LightRay cannot assert the innocent owner defense.34 32 Id. (quoting 18 U.S.C. § 983 (d)(6)(B)(i)). 33 Id. at 373 (quoting Schenley Distillers Corp. v. United States, 326 U.S. 432, 437 (1946)); see also First Beneficial, 2009 WL 1035233 , at *4 (“The law cannot allow a sole corporate shareholder to disregard the corporate entity when it suits him and allow him the benefit of the corporate entity when he desires.”). 34 See, e.g., United States v. …
discussed Cited as authority (rule) United States Ex Rel. Williams v. Renal Care Group, Inc.
6th Cir. · 2012 · confidence medium
The corporate form need not be disregarded when its adoption was meant to “secure its advantages and where no violence to the legislative purpose is done by treating the corporate entity as a separate legal person.” Schenley Distillers Corp. v. United States, 326 U.S. 432, 437 (1946).
cited Cited as authority (rule) Alcoa, Inc. v. Tennessee State Board of Equalization
Tenn. Ct. App. · 2011 · confidence medium
Id. (quoting Schenley Distillers Corporation v. United States, 326 U.S. 432, 437 , 66 S.Ct. 247, 249 , 90 L.Ed. 181, 184 (1946)).
discussed Cited as authority (rule) CAO Holdings, Inc. v. Loren L. Chumley, Commissioner of Revenue, State of Tennessee
Tenn. Ct. App. · 2009 · confidence medium
The 24 trips for which the plane was used during CAO’s ownership do not include the two flights around W ichita, Kansas on the day CAO purchased the plane, which were presumably test flights, and the delivery flight from W ichita, Kansas to Knoxville, Tennessee. 9 At the time CAO purchased the airplane at issue, Mr. Clayton had access to a Bell helicopter, which he owned in his individual capacity, and a Cessna Five Ultra Business Jet, which was owned by Clay Air, an entity controlled by Mr. Clayton. -7- legislative purpose, they will not be disregarded where those in control have deliberate…
examined Cited as authority (rule) Semande v. Estes (7×) also: Cited "see"
Ill. App. Ct. · 2007 · confidence medium
Ed. 181, 184 , 66 S. Ct. 247, 249 (1946); Board of Transportation v. Martin, 296 N.C. 20, 29 , 249 S.E.2d 390, 396 (N.C.
discussed Cited as authority (rule) Copperweld Corp. v. Independence Tube Corp. (2×) also: Cited "see, e.g."
SCOTUS · 1984 · confidence medium
See also Monsanto Co. v. Spray-Rite Service Co., 465 U. S., at 764, n. 9 . [12] E. g., Associated General Contractors of California, Inc. v. Carpenters, 459 U. S. 519, 531-532 (1983); National Society of Professional Engineers v. United States, 435 U. S. 679, 687-688 (1978); Standard Oil, 221 U. S., at 59 . [13] See, e. g., Schenley Corp. v. United States, 326 U. S. 432, 437 (1946) (per curiam) ; New Colonial Ice Co. v. Helvering, 292 U. S. 435, 440-442 (1934); Burnet v. Clark, 287 U. S. 410 (1932); Louisville, C. & C.
cited Cited as authority (rule) Cook Export Corp. v. King
Tenn. · 1981 · confidence medium
Schenley Distillers Corp. v. United States, 326 U.S. 432, 437 , 66 S.Ct. 247, 249 , 90 L.Ed. 181, 184 (1946).’” 221 Tenn. at 607-608 , 429 S.W.2d at 817-818 .
discussed Cited as authority (rule) Bangor Punta Operations, Inc. v. Bangor & Aroostook Railroad (2×)
SCOTUS · 1974 · confidence medium
As this Court *729 has frequently recognized, equity should pierce the corporate veil only when necessary to serve some paramount public interest, see Schenley Corp. v. United States, 326 U. S. 432, 437 (1946); Anderson v. Abbott, 321 U. S. 349, 362 (1944), or "where it otherwise would present an obstacle to the due protection or enforcement of public or private rights." New Colonial Ice Co. v. Helvering, 292 U. S., at 442 .
cited Cited as authority (rule) Abbott Widdicombe v. McGuire
Tenn. · 1968 · confidence medium
Schenley Distillers Corporation v. United States, 326 U.S. 432, 437 , 66 S.Ct. 247, 249 , 90 L.Ed. 181, 184 (1946).
cited Cited as authority (rule) Central & Southern Motor Freight Tariff Ass'n v. United States
D. Del. · 1967 · signal: cf. · confidence medium
Cf., Schenley Distillers Corp. v. United States, 326 U.S. 432, 437 [ 66 S.Ct. 247 , 90 L.Ed. 181 ] (1946).
discussed Cited as authority (rule) Licorería Trigo, Inc. v. Secretary of the Treasury
prsupreme · 1967 · confidence medium
Candal & Co. v. Rivero, 86 P.R.R. 481 , 486 (1962), “To decide the contrary in this case would be to permit the use of the corporate fiction to evade compliance with legitimate obligations.” 7 Schenley Distillers Corp. v. United States, 326 U.S. 432, 437 (1946); South Porto Rico Sugar Corp. v. Sugar Board, 88 P.R.R. 42 (1963) and authorities therein cited.
discussed Cited as authority (rule) Licorería Trigo, Inc. v. Secretario de Hacienda
prsupreme · 1967 · confidence medium
Candal & Co. v. Rivera, 86 D.P.R. 508, 513 (1962), “resolver lo contrario en este caso sería permitir el uso del artificio corporativo para evadir el cumplimiento de obligaciones legí-timas.” (7) Schenley Corp. v. United States, 326 U.S. 432, 437 (1946); South P.R.
cited Cited as authority (rule) South Porto Rico Sugar Corp. v. Sugar Board
prsupreme · 1963 · confidence medium
Schenley Distillers Corporation v. United States, 326 U.S. 432, 437 (1946).
cited Cited as authority (rule) South Porto Rico Sugar Corp. v. Junta Azucarera
prsupreme · 1963 · confidence medium
Las entidades corporativas pueden descartarse cuando son instrumentos para evadir un claro propósito legislativo, Schenley Distillers Corporation v. U.S., 326 U.S. 432, 437 (1946).
cited Cited "see" Ronnoco Coffee LLC v. Castgna
E.D. Mo. · 2021 · signal: see · confidence high
See Schenley Distillers Corp. v. U.S., 326 U.S. 432, 435 (1946).
cited Cited "see" Ronnoco Coffee LLC v. Peoples
E.D. Mo. · 2021 · signal: see · confidence high
See Schenley Distillers Corp. v. U.S., 326 U.S. 432, 435 (1946).
examined Cited "see" Securities Industry & Financial Markets Ass'n v. United States Commodity Futures Trading Commission (7×) also: Cited "see, e.g."
D.D.C. · 2014 · signal: accord · confidence high
Airways Charters, Inc. v. Regan, 746 F.2d 865 , 873 n. 14 (D.C.Cir.1984); accord Schenley Distillers Corp. v. United States, 326 U.S. 432, 435 , 66 S.Ct. 247 , 90 L.Ed. 181 (1946). 12 To establish standing pursuant to these established principles, the plaintiff associations must identify for each challenged Title VII Rule at least one member of one of their associations that is regulated or directly harmed by that Rule’s extraterritorial application.
examined Cited "see" James Cottrill v. Patrick Mirandy, Warden (3×)
W. Va. · 2013 · signal: see · confidence high
See Southern State Cooperative, Inc. v. Dailey, 167 W.Va. 920, 930-31 , 280 S.E.2d 821, 827 (1981) (quoting Schenley Distillers Corp. v. United States, 326 U.S. 432, 437 , 66 S.Ct. 247, 249 , 90 L.Ed. 181, 184 (1945)). -3-
examined Cited "see" Semande v. Estes (3×)
Ill. App. Ct. · 2007 · signal: see · confidence high
See Schenley Distillers Corp. v. United States, 326 U.S. 432, 437 , 66 S. Ct. 247, 249 , 90 L.
examined Cited "see" In Re Thomson McKinnon Securities, Inc. (3×)
Bankr. S.D.N.Y. · 1992 · signal: see · confidence high
See Schenley Distillers Corporation v. United States, 326 U.S. 432, 437 , 66 S.Ct. 247, 249 , 90 L.Ed. 181 (1946); Coast Mfg.
cited Cited "see" Nantahala Power & Light Co. v. Thornburg
SCOTUS · 1986 · signal: see · confidence high
See Schenley Distillers Corp. v. United States, 326 U. S. 432, 437 (1946) (per curiam).
examined Cited "see" Tennessee Valley Authority v. Exxon Nuclear Company, Inc., and Exxon Corporation (3×)
6th Cir. · 1985 · signal: see · confidence high
See generally Schenley Distillers Corp. v. U.S., 326 U.S. 432 , 66 S.Ct. 247 , 90 L.Ed. 181 (1946); Volasco Products *498 Company v. Lloyd A. Fry Roofing Co., 308 F.2d 383 (6th Cir.1962), cert. denied, 372 U.S. 907 , 83 S.Ct. 721 , 9 L.Ed.2d 717 (1963); Miles v. American Telephone and Telegraph Company, 703 F.2d 193 (5th Cir.1983).
examined Cited "see" Tennessee Valley Authority v. Exxon Nuclear Co. (3×)
E.D. Tenn. · 1983 · signal: see · confidence high
See Schenley Distillers Corp. v. United States, 326 U.S. 432, 436-437 , 66 S.Ct. 247, 249 , 90 L.Ed. 181 (1946); see also, Volasco Products Co. v. Lloyd A. Fry Roofing Co., 308 F.2d 383, 394 (6th Cir.1962), cert. denied, 372 U.S. 907 , 83 S.Ct. 721 , 9 L.Ed.2d 717 (1963).
examined Cited "see" Aero Mayflower Transit Company, Inc. v. Interstate Commerce Commission (3×)
D.C. Cir. · 1983 · signal: see · confidence high
See Schenley Distillers Corp. v. United States, 326 U.S. 432, 436-437 , 66 S.Ct. 247, 249 , 90 L.Ed. 181, 184 (1946) 11 See Protests of Global Van Lines, Inc., et al., supra note 2, J.App. 36-82.
examined Cited "see" Aero Mayflower Transit Co. v. Interstate Commerce Commission (3×)
D.C. Cir. · 1983 · signal: see · confidence high
See Schenley Distillers Corp. v. United States, 326 U.S. 432, 436-437 , 66 S.Ct. 247, 249 , 90 L.Ed. 181, 184 (1946). .
examined Cited "see" General Telephone Co. of Southwest v. United States (3×)
5th Cir. · 1971 · signal: see · confidence high
Mansfield Journal Co. v. FCC, 86 U.S.App.D.C. 102 , 180 F.2d 28 (1950); see Schenley Distillers Corp. v. United States, 326 U.S. 432 , 66 S.Ct. 247 , 90 L.Ed. 181 (1946); Kavanaugh v. Ford Motor Co., 353 F.2d 710 (C.A. 7, 1965).
examined Cited "see" General Telephone Company of Southwest v. United States (3×)
5th Cir. · 1971 · signal: see · confidence high
Mansfield Journal Co. v. FCC, 86 U.S.App.D.C. 102 , 180 F.2d 28 (1950); see Schenley Distillers Corp. v. United States, 326 U.S. 432 , 66 S.Ct. 247 , 90 L.Ed. 181 (1946); Kavanaugh v. Ford Motor Co., 353 F.2d 710 (C.A. 7, 1965).
examined Cited "see" El Salto, S.A., Escuintla, Guatemala, C.A. v. Psg Co., El Salto, S.A., Escuintla, Guatemala, C.A. v. Philip S. Greenberg, El Salto, S.A., Escuintla, Guatemala, C.A. v. Philip S. Greenberg (3×)
9th Cir. · 1971 · signal: see · confidence high
See Schenley Distillers Corp. v. United States, 326 U.S. 432, 437 , 66 S.Ct. 247 , 90 L.Ed. 181 (1946).
examined Cited "see" El Salto, S.A. v. PSG Co. (3×)
9th Cir. · 1971 · signal: see · confidence high
See Schenley Distillers Corp. v. United States, 326 U.S. 432, 437 , 66 S.Ct. 247 , 90 L.Ed. 181 (1946).
examined Cited "see" Charlotte Klinger and Eric Klinger v. The Baltimore and Ohio Railroad Company, and Edward C. Rose (6×)
2d Cir. · 1970 · signal: see · confidence high
See Schenley Distillers Corp. v. United States, 326 U.S. 432 , 66 S.Ct. 247 , 90 L.Ed. 181 (1945).
examined Cited "see" Leitchfield Manufacturing Co. v. United States (3×)
W.D. Ky. · 1970 · signal: see · confidence high
See Schenley Distillers Corp. v. United States, 326 U.S. 432 , 66 S.Ct. 247 , 90 L.Ed. 181 (1946); Lukens Steel Co., Contract Carrier Application, 42 M.C.C. 672 (1943); Lee Wilson & Co., Contract Carrier Application, 29 M.C.C. 525 (1941).
examined Cited "see" United States v. William H. Webb (3×)
4th Cir. · 1968 · signal: see · confidence high
See Schenley Distillers Corp. v. United States, 61 F.Supp. 981, 987 (Del. 1945), aff’d, 326 U.S. 432 , 66 S.Ct. 247 , 90 L.Ed. 181 (1946); Shippers Cooperative, Inc., et al. v. I.
discussed Cited "see" Boutell v. Walling (2×)
SCOTUS · 1946 · signal: see · confidence high
See Schenley Distillers Corp. v. United States, 326 U. S. 432 , for a case giving effect to certain other consequences under the Motor Carrier Act of a corporate arrangement chosen by the persons concerned as a means of carrying on their business.
discussed Cited "see, e.g." Hi-Vac Corporation v. Coley
S.D. Ohio · 2024 · signal: see also · confidence medium
Tenn. 2011); see also Schenley Distillers Corp. v. U.S., 326 U.S. 432, 435 (1946) (parent corporation has no standing to sue to set aside commission’s order denying its subsidiary’s permit); Pepsico, Inc. v. N.L.R.B., 382 F.2d 265, 266 (6th Cir. 1967) (parent corporation could not challenge N.L.R.B. ruling on behalf of its wholly owned subsidiary); Media Gen., Inc. v. Tanner, 625 F. Supp. 237, 244 (W.D.
examined Cited "see, e.g." Rochester Gas & Electric Corp. v. GPU, Inc. (3×)
2d Cir. · 2009 · signal: see also · confidence low
Edison Co. of N.Y. v. UGI Utils., Inc., 423 F.3d 90, 94 (2d Cir.2005) (internal quotation marks and alterations omitted); see also Schenley Distillers Corp. v. United States, 326 U.S. 432, 437 , 66 S.Ct. 247 , 90 L.Ed. 181 (1946) (observing that “corporate entities may be disregarded where they are made the implement for avoiding a clear legislative purpose”).
examined Cited "see, e.g." In Re Finley, Kumble, Wagner, Heine, Underberg (3×)
Bankr. S.D.N.Y. · 1994 · signal: see also · confidence low
Jonas v. State, 19 Wis.2d 638 , 121 N.W.2d 235 (1963); see also Schenley Distillers Corp. v. United States, 326 U.S. 432 , 66 S.Ct. 247 , 90 L.Ed. 181 (1946) (corporate form will not be disregarded where those in control have deliberately adopted the corporate form in order to secure its advantages and where no violence to the legislative purpose is done by treating the corporate entity as a separate legal person); Maley v. Carroll, 381 F.2d 147 (5th Cir.1967); Gregory v. Garrett Corp., 578 F.Supp. 871 (S.D.N.Y.1983).
examined Cited "see, e.g." In Re AV Jellen (3×)
N.D.W. Va. · 1981 · signal: see, e.g. · confidence low
See, e. g., Schenley Corp. v. United States, 326 U.S. 432, 437 , 66 S.Ct. 247, 249 , 90 L.Ed. 181 (1946).
discussed Cited "see, e.g." Jules Inc. v. Boggs (2×)
W. Va. · 1980 · signal: see also · confidence low
See also Schenley Distillers Corp. v. *520 United States 326 U.S. 432 , 66 S.Ct. 247 , 90 L.Ed 181 (1946).
examined Cited "see, e.g." Edward C. Carey, and New England Petroleum Corporation v. National Oil Corporation and Libyan Arab Republic (3×)
2d Cir. · 1979 · signal: see, e.g. · confidence low
See, e. g., Schenley Distillers Corp. v. United States, 326 U.S. 432, 437 , 66 S.Ct. 247 , 90 L.Ed. 181 (1946); Commissioner of Internal Revenue v. Schaefer, 240 F.2d 381, 383 (2d Cir. 1957); Boise Cascade Corp. v. Wheeler, 419 F.Supp. 98, 102 (S.D.N.Y.1976), aff’d, 556 F.2d 554 (2d Cir. 1977). 7 .
examined Cited "see, e.g." Carl Norman Quinn v. Earl L. Butz, Secretary of Agriculture, and United States of America (3×)
D.C. Cir. · 1975 · signal: see, e.g. · confidence low
See, e. g., Schenley Distillers Corp. v. United States, 326 U.S. 432, 436-437 , 66 S.Ct. 247 , 90 L.Ed. 181 (1946). 99 .
Retrieving the full opinion text from the archive…
SCHENLEY DISTILLERS CORP. Et Al.
v.
UNITED STATES Et Al.
560.
Supreme Court of the United States.
Jan 2, 1946.
326 U.S. 432
Mr. Charles E. Cotterill for appellants., Solicitor General McGrath and Mr. J. Stanley Payne for the United States and the Interstate Commerce Commission, appellees.
Jackson, Per Curiam.
Cited by 132 opinions  |  Published
2 passages pin-cited by 2 cases
Pinpoint authority: bottom 75%
Citer courts: D. Delaware (3) · M.D. Tennessee (3)
Per Curiam.

This is an appeal from a judgment of a district court, three judges sitting, constituted under the Urgent Deficiencies Act, 38 Stat. 220, 28 U. S. C. § 47, dismissing appellants’ petition to set aside an order of the Interstate Commerce Commission. Appellant Schenley Distilleries Motor Division, Inc., applied to the commission for a permit, under § 209 (b) of Part II of the Interstate Commerce Act, 49 U. S. C. §309 (b), authorizing operation as a “contract carrier by motor vehicle” of specified commodities in interstate commerce between specified points. At the outset of the proceedings before the commission, the appellant moved for dismissal of the application on the ground that the proposed operations were not such as to constitute applicant a. “contract carrier by motor vehicle,” defined by § 203 (a) (15) of the Act, 49 U. S. C.[*434] § 303 (a) (15), as “any person which, under individual contracts or agreements, engages in the transportation (other than transportation referred to in paragraph (14) and the exception therein) by motor vehicle of passengers or property in interstate or foreign commerce for compensation.”

Applicant contended at the hearing that it was a “private carrier of property by motor vehicle,” which is defined by § 203 (a) (17) as “any person not included in the terms ‘common carrier by motor vehicle’ or ‘contract carrier by motor vehicle’, who or which transports in interstate or foreign commerce by motor vehicle property of which such person is the owner, lessee, or bailee, when such transportation is for the purpose of sale, lease, rent, or bailment, or in furtherance of any commercial enterprise.”

Applicant introduced no evidence to prove compliance with the requirements set forth by § 209 (b) for granting a permit as a “contract carrier” but sought a ruling by the commission that it could carry on its operations as a “private carrier” without obtaining a permit. Stating that “the primary reason for filing this application was to secure a determination as to whether the involved operations were those, of a contract carrier of property by motor vehicle or of a private carrier,” Division 5 of the commission in its report ruled that the applicant was a “contract carrier” and not a “private carrier.” As no evidence had been introduced to show that the proposed operations would comply with § 209 (b), Division 5 made its order denying the application, and made the report a part of the order. Reconsideration by the full commission was denied.

This suit to set aside the commission’s order was brought by the applicant, Schenley Distilleries Motor Division, and by Schenley Distillers Corporation, owner of all the[*435] stock of the former. The district court held that it had jurisdiction to review the order. It dismissed the suit as to the parent corporation on the ground that it had no legal interest sufficient to entitle it to maintain suit. The court held that the commission properly ruled that the applicant was a “contract carrier,” and accordingly dismissed the complaint.

The district court rightly held that the parent corporation had no standing to sue. It did not ask that a permit be issued to it, and its sole interest in the permit sought for its co-appellant was that of a stockholder. We have held that a minority stockholder of a carrier corporation cannot bring suit to set aside a commission order against the corporation. Pittsburgh & W. Va. R. Co. v. United States, 281 U. S. 479, 486-488. A parent corporation which by its stock ownership controls its subsidiary, and which as a party litigant asserts only its stockholder’s derivative rights to have its subsidiary secure the permit, cf. American Power Co. v. S. E. C., 325 U. S. 385, 389, is even less aggrieved by the commission’s order denying the permit than would be a minority stockholder. For the parent is adequately represented for purposes of suit by the subsidiary whose conduct of the litigation it controls. We conclude that the character of a stockholder’s interest in this regard is not so altered by the mere facts that it owns all the stock of the corporation against which the commission’s order is entered and that the parent manages and controls its subsidiary, as to give the stockholder standing to sue to set aside the commission’s order.

As to appellant Schenley Distilleries Motor Division, Inc., the appellee urges that the judgment should be affirmed on the ground that the appellant made no showing sufficient to require the issuance of the permit sought by the application and that thus the commission’s order rests on a controlling ground, i. e., lack of evidence. But there[*436] remains the question whether the commission’s determination that appellant will be a “contract carrier” is reviewable in the present suit. The commission made its report a part of its order, and the report denied the relief which appellant sought, namely, a determination that it was a “private carrier” entitled to carry on its operations without a permit and without subjecting itself to criminal proceedings. The commission has treated the filing of an application under § 209 (b) with a request that the application be dismissed on the ground that it is not required, as a proper method of raising the issue whether the applicant is subject to the Act. Any other construction of that section would make it necessary for a carrier to take the risk of operating illegally and incurring criminal and other penalties in order to secure a determination whether it is within the permit requirement. We have already decided that the course followed here was “appropriate,” and that an order determining that the appellant is within the permit requirement is a reviewable order. Cornell Steamboat Co. v. United States, 321 U. S. 634, 635. We reaffirm that holding.

We think the district court was plainly right in upholding the commission’s decision that appellant’s proposed operations would constitute it a “contract” rather than a “private” carrier. Appellant’s contention to the contrary is based on the fact that its operations were to be performed for its parent and for other corporations owned or controlled by the parent, ' Appellant says that the transportation will be in furtherance of one “commercial enterprise” within the meaning of §203 (a) (17). But that section applies only to the extent to which § 203 (a) (15). does not, and the evidence supports the commission’s finding that the transportation- was to- be “for compensation” from appellant’s parent,, and the other corporations controlled by the parent. -Appellant urges that we dis[*437] regard the separate corporate entities which are to pay compensation to appellant for the transportation and treat the corporations controlled by appellant’s parent as one single commercial enterprise. While corporate entities may be disregarded where they are made the implement for avoiding a clear legislative purpose, they will not be disregarded where those in control have deliberately adopted the corporate form in order to secure its advantages and where no violence to the legislative purpose is done by treating the corporate entity as a separate legal person. One who has created a corporate arrangement, chosen as a means of carrying out his business purposes, does not have the choice of disregarding the corporate entity in order to avoid the obligations which the statute lays upon it for the protection of the public.

The fact that several corporations are used in carrying on one business does not relieve them of their several statutory obligations more than it relieves them of the taxes severally laid upon them. “If the one business could not be carried on without two corporations taking part in it, each must pay, by the plain words of the Act.” Edwards v. Chile Copper Co., 270 U. S. 452, 456. Cf. Gray v. Powell, 314 U. S. 402, 414; Moline Properties v. Commissioner, 319 U. S. 436.

Affirmed.

Mr. Justice Jackson took no part in the consideration or decision of this case.