Manchester Sav. Bank & Trust Co. v. Commissioner
United States Board of Tax Appeals
CONSOLIDATED RETURNS - COMPUTATION OF PROFIT DERIVED UPON LIQUIDATION OF SUBSIDIARY. - Petitioner and its wholly owned subsidiary filed consolidated returns for the years 1917 to 1931, inclusive, and for the year 1932 petitioner filed a separate return. The subsidiary sustained operating losses in the prior years, which were used in consolidated returns to reduce petitioner's taxable income.
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CONSOLIDATED RETURNS - COMPUTATION OF PROFIT DERIVED UPON LIQUIDATION OF SUBSIDIARY. - Petitioner and its wholly owned subsidiary filed consolidated returns for the years 1917 to 1931, inclusive, and for the year 1932 petitioner filed a separate return. The subsidiary sustained operating losses in the prior years, which were used in consolidated returns to reduce petitioner's taxable income. The subsidiary was liquidated in 1932. Held, in computing the taxable profit derived by petitioner from such liquidation, the cost basis of the subsidiary's stock should be reduced by the aggregate amount…
1Opinion of the Court
MANCHESTER SAVINGS BANK AND TRUST COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Manchester Sav. Bank & Trust Co. v. Commissioner
Docket No. 79658.
United States Board of Tax Appeals
34 B.T.A. 1008; 1936 BTA LEXIS 608;
September 29, 1936, Promulgated
CONSOLIDATED RETURNS - COMPUTATION OF PROFIT DERIVED UPON LIQUIDATION OF SUBSIDIARY. - Petitioner and its wholly owned subsidiary filed consolidated returns for the years 1917 to 1931, inclusive, and for the year 1932 petitioner filed a separate return. The subsidiary sustained operating losses in the prior years, which were used…
2Cases cited4 opinions
- Burnet v. Aluminum Goods Manufacturing Co.Supreme Court of the United States · 1933
- Riggs Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1929
- National Casket Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Manchester Sav. Bank & Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1936