Roessler & Hasslacher Chemical Co. v. Commissioner
United States Board of Tax Appeals
Where any distribution or apportionment of deductions is proper under section 240(d) of the Revenue Act of 1921, it is incumbent upon the petitioner to prove an apportionment which is as accurate as reasonably may be under the circumstances.
1Opinion of the Court
*919OPINION.
Mukdock:
The R. & H. Company filed consolidated returns for 1921 and 1922 on behalf of itself, Niagara, and four other companies. The Commissioner has removed Niagara from the alleged affiliation and has computed its tax liability separately. There is no controversy about the figures which he has used in making this determination. The petitioner contends that certain expenditures of the R. & H. Company for each year should be distributed or apportioned so that a part thereof may be used to offset Niagara’s income, another part used to offset the income of Perth Amboy, and the remainder…
2Cited by5 opinions
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