“ While unusual cases may require disregard of corporate form, we think the record here fails to disclose any circumstances sufficient to support the petitioner's claim. Certainly the improvement company and the estate were separate and distinct entities; the former was avowedly utilized to bring about a change in ownership beneficial to the latter. For years they were recognized and treated as differentthings and taxed accordingly upon separate returns. The situation is not materially different from the not infrequent one where a corporation is controlled by a single stockholder. ”

“ Counsel for respondent concede that ordinarily a corporation and its stockholders are separate entities, whether the shares are divided among many or are owned by one. Consequently they make no effort to support any general rule under which a corporation and its single stockholder have such identity of interest that transactions between them must be disregarded for tax purposes. ”

“ In 1919 the improvement company, under privilege extended to stockholders, subscribed for and received 75,000 new shares then issued by the British-American Company. Paying therefor $326,437.50-$4.3525 per share-much less than market value.
In 1920 the trustees of the estate acquired the $4,000,000 of respondent's debentures theretofore deposited for benefit of the school. These were transferred to respondent, and in part payment it transferred to the estate the original block (the identical certificates) of 225,000 British-American Tobacco Company shares volued at $5,287,500-$23.50 per share. ”