Handy & Harman v. Commissioner
United States Board of Tax Appeals
1. The Commissioner had authority to reconsider and reverse the determination of his predecessor in office that the petitioner and Hamilton & DeLoss, Inc., were affiliated during the year 1918 and the period January 1 to February 1, 1919. 2. The petitioner and Hamilton & DeLoss, Inc., were not affiliated during the year 1918 and the period January 1 to February 1, 1919, within the meaning of section 240 of the Revenue Act of 1918.
1Opinion of the Court
*984OPINION.
Marquette:
The first issue raised by the pleadings herein is whether Commissioner Blair had authority to reverse and set aside the finding of his predecessor in office that the petitioner and Hamilton & DeLoss, Inc., were affiliated during the year 1918 and the period January 1 to February 1, 1919, and entitled to file consolidated returns of net income and invested capital. This issue must be resolved in favor of the respondent, on the authority of Yokohama Ki-Ito Kwaisha, Ltd., 5 B. T. A. 1248; Estate of W. S. Tyler, 9 B. T. A. 255; James Couzens, 11 B. T. A. 1040; Rosetta V. Hauss,…
2Cases cited1 opinion
- In re Temtor Corn & Fruit Products Co.District Court, E.D. Missouri · 1924
3Cited by1 opinion
- Handy & Harman v. CommissionerUnited States Board of Tax Appeals · 1929