General Finance Co. v. Commissioner
United States Board of Tax Appeals
The petitioner is a Pennsylvania corporation, chartered January 20, 1930. It is the domestication under the laws of the Commonwealth of Pennsylvania of a corporation by the same name chartered by the State of Delaware August 31, 1921. The Delaware corporation had net losses for the years 1928 and 1929 which the petitioner seeks to deduct from gross income in computing its tax liability of 1930. Held, that the net losses of the Delaware corporation are not legal deductions…
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The petitioner is a Pennsylvania corporation, chartered January 20, 1930. It is the domestication under the laws of the Commonwealth of Pennsylvania of a corporation by the same name chartered by the State of Delaware August 31, 1921. The Delaware corporation had net losses for the years 1928 and 1929 which the petitioner seeks to deduct from gross income in computing its tax liability of 1930. Held, that the net losses of the Delaware corporation are not legal deductions from the income of the petitioner for 1930.
1Opinion of the Court
opinion.
Smith :
This proceeding is for the redetermination of deficiencies for the period January 20 to December 31,1930, and for the calendar year 1931 in the amounts of $811.63 and $1,690.93, respectively. The petition alleges:
4. The determination of the taxes as sot forth in said notice of deficiency is based upon the following errors:
A. In determining the taxable net income of the petitioner for the year 1930, the Commissioner erroneously disallowed a statutory net loss of $24,808.52 for the years 1928 and 1929. The Commissioner has erroneously disallowed this loss upon the basis that the…
2Cases cited13 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Railway Co. v. Whitton's AdministratorSupreme Court of the United States · 1872
- Railroad Company v. HarrisSupreme Court of the United States · 1871
- Wong Doo v. United StatesSupreme Court of the United States · 1924
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