Legal Opinion

Joseph & Feiss Co. v. Commissioner

United States Board of Tax Appeals

Decided October 31, 1932No. Docket No. 46465Published

Petitioner sustained a net loss in 1925. On May 5, 1926, it became affiliated with another corporation, and thereafter filed a consolidated return for the year 1926. Held, separate returns were required for the periods of 1926 before and after affiliation, and that each such period was a "taxable year" within the meaning of section 200(a) of the Revenue Act of 1926, for the purpose of applying the net loss sustained in 1925. Weissberger Moving & Storage Co.,26 B.T.A. 1375,…

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Petitioner sustained a net loss in 1925. On May 5, 1926, it became affiliated with another corporation, and thereafter filed a consolidated return for the year 1926. Held, separate returns were required for the periods of 1926 before and after affiliation, and that each such period was a "taxable year" within the meaning of section 200(a) of the Revenue Act of 1926, for the purpose of applying the net loss sustained in 1925. Weissberger Moving & Storage Co.,26 B.T.A. 1375, followed.

1Opinion of the Court

THE JOSEPH & FEISS COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Joseph & Feiss Co. v. Commissioner

Docket No. 46465.

United States Board of Tax Appeals

26 B.T.A. 1424; 1932 BTA LEXIS 1151;

October 31, 1932, Promulgated

Petitioner sustained a net loss in 1925. On May 5, 1926, it became affiliated with another corporation, and thereafter filed a consolidated return for the year 1926. Held, separate returns were required for the periods of 1926 before and after affiliation, and that each such period was a "taxable year" within the meaning of section 200(a) of the Revenue Act…

2Cases cited2 opinions

  1. Weissberger Moving & Storage Co. v. CommissionerUnited States Board of Tax Appeals · 1932
  2. Joseph & Feiss Co. v. CommissionerUnited States Board of Tax Appeals · 1932

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