Pittsburgh & W. Va. Ry. v. Commissioner
United States Board of Tax Appeals
1. TAXABLE PERIODS FOR INCOME TAX UNDER REVENUE ACTS OF 1916 AND 1917, AND WAR EXCESS PROFITS TAX UNDER REVENUE ACT OF 1917. - Where a corporation was in existence during the entire calendar year 1917, but was a member of an affiliated group for the first three months of such year, and a member of another affiliated group with a different parent company for the last nine months of such year, held, that its taxable period for income tax purposes is the calendar year 1917, and…
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1. TAXABLE PERIODS FOR INCOME TAX UNDER REVENUE ACTS OF 1916 AND 1917, AND WAR EXCESS PROFITS TAX UNDER REVENUE ACT OF 1917. - Where a corporation was in existence during the entire calendar year 1917, but was a member of an affiliated group for the first three months of such year, and a member of another affiliated group with a different parent company for the last nine months of such year, held, that its taxable period for income tax purposes is the calendar year 1917, and its taxable periods for was excess profits tax purposes are the three and nine-month periods, respectively. Trustees…
1Opinion of the Court
*67OPINION.
Black:
This is a reconsideration of our Division report promulgated May 31, 1934 (30 B. T. A. 843), which involved proceedings that grew out of proceedings originally commenced at Docket No. 8349. The caption of the petition in Docket No. 8349 was “Appeal of The Pittsburgh & West Virginia Railway Company and Affiliated Companies Hereinafter Mentioned ”, and in the opening paragraph the petition recited in part as follows :
The above named taxpayer, The Pittsburgh & West Virginia Railway Company, its predecessor company, the Wabash Pittsburgh Terminal Railway Company, and its affiliated…
2Cases cited2 opinions
- Burnet v. Aluminum Goods Manufacturing Co.Supreme Court of the United States · 1933
- Bankers' Trust Co. v. BowersCourt of Appeals for the Second Circuit · 1923
3Cited by9 opinions
- Century Data Systems, Inc. v. CommissionerUnited States Tax Court · 1983
- Schick v. CommissionerUnited States Tax Court · 1966
- California Brewing Asso. v. CommissionerUnited States Board of Tax Appeals · 1941
- Century Data Systems, Inc. v. CommissionerUnited States Tax Court · 1983
- Edwards v. CommissionerUnited States Tax Court · 1955
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