Norwich Woolen Mills Corp. v. Commissioner
United States Board of Tax Appeals
1. On March 7, 1921, the stock of the taxpayer corporation was acquired by the petitioner corporation. Petitioner caused the taxpayer to be dissolved on that day and took over its assets. Thereafter petitioner continued the business. Held, that the taxpayer and the petitioner were separate taxable entities and each is required to file a return reporting its income from the business.
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1. On March 7, 1921, the stock of the taxpayer corporation was acquired by the petitioner corporation. Petitioner caused the taxpayer to be dissolved on that day and took over its assets. Thereafter petitioner continued the business. Held, that the taxpayer and the petitioner were separate taxable entities and each is required to file a return reporting its income from the business. A return by petitioner of income earned by the taxpayer prior to March 7, 1921, is not a proper return. 2. In determining the income of a business during a portion of a year by apportioning the earnings of the…
1Opinion of the Court
NORWICH WOOLEN MILLS CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Norwich Woolen Mills Corp. v. Commissioner
Docket No. 23375.
United States Board of Tax Appeals
18 B.T.A. 303; 1929 BTA LEXIS 2080;
November 21, 1929, Promulgated
1. On March 7, 1921, the stock of the taxpayer corporation was acquired by the petitioner corporation. Petitioner caused the taxpayer to be dissolved on that day and took over its assets. Thereafter petitioner continued the business. Held, that the taxpayer and the petitioner were separate taxable entities and each is required to file a return…
2Cases cited1 opinion
- Norwich Woolen Mills Corp. v. CommissionerUnited States Board of Tax Appeals · 1929