Southern Power Co. v. Commissioner
United States Board of Tax Appeals
1. Where one of several corporations which were affiliated elected to file a separate return, other members of the group of affiliated corporations may not file a consolidated return of their income. Action of the Commissioner in computing the tax liability of one of such corporations on the basis of its separate income approved. 2. Interest which accrued and was paid during the taxable year held to be income to the recipient.
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1. Where one of several corporations which were affiliated elected to file a separate return, other members of the group of affiliated corporations may not file a consolidated return of their income. Action of the Commissioner in computing the tax liability of one of such corporations on the basis of its separate income approved. 2. Interest which accrued and was paid during the taxable year held to be income to the recipient. It is immaterial that the earnings of the debtor were insufficient to pay such interest, or that such interest was paid from funds loaned to the debtor by the creditor.
1Opinion of the Court
SOUTHERN POWER CO. ET AL., PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Southern Power Co. v. Commissioner
Docket No. 28561.
United States Board of Tax Appeals
17 B.T.A. 962; 1929 BTA LEXIS 2208;
October 16, 1929, Promulgated
1. Where one of several corporations which were affiliated elected to file a separate return, other members of the group of affiliated corporations may not file a consolidated return of their income. Action of the Commissioner in computing the tax liability of one of such corporations on the basis of its separate income approved.
2. Interest which accrued and…
2Cases cited3 opinions
- Apartment Corp. v. CommissionerUnited States Board of Tax Appeals · 1929
- Southern Power Co. v. CommissionerUnited States Board of Tax Appeals · 1929
- B. B. Bathing Park, Inc. v. CommissionerUnited States Board of Tax Appeals · 1929