Rogan

This is an appeal from a judgment against appellant corporation for a capital stock tax for the taxable year ending June 30, 1936. Appellant claims that it was not liable since it was not carrying on or doing any business for any part of that tax year and hence was not liable for the tax imposed by section 105 (a) of the Revenue Act of 1935, as amended, 26 U.S.C.A. Int.Rev. Acts, page 796.

The question here is whether certain acts of appellant in aid of a wholly owned subsidiary corporation, with respect to securing for the subsidiary a lease of a store building in which the latter conducted a part of its business of selling furniture and home furnishings, constituted “doing business” within the meaning of that section.

Section 105(a), as amended, provides:

“For each year ending June 30, beginning with the year ending June 30, 1936, there is hereby imposed upon every domestic corporation with respect to carrying on or doing business for any part of such year an excise tax of $1 for each $1,000 of the adjusted declared value of its capital stock.”

Article 42 of Treasury Regulations 64 for the year 1936 relating to Section 105(a) embodies in its definition of the term “doing…