Legal Opinion

Lawyers' Bldg. Corp. v. Commissioner

United States Board of Tax Appeals

Decided February 23, 1937No. Docket Nos. 81460, 81461, 81462, 81463, 81464PublishedCited by 3 opinions

Petitioners, together with 10 other corporations, were affiliated. December 1, 1932, the Savoy-Plaza Corporation, a subsidiary affiliate, was adjudicated bankrupt. For the calendar year 1932, the parent of the affiliated group filed a so-called consolidated return, including the income of all affiliates except that of the Savoy-Plaza Corporation.

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Petitioners, together with 10 other corporations, were affiliated. December 1, 1932, the Savoy-Plaza Corporation, a subsidiary affiliate, was adjudicated bankrupt. For the calendar year 1932, the parent of the affiliated group filed a so-called consolidated return, including the income of all affiliates except that of the Savoy-Plaza Corporation. All such affilates filed form 1122, authorizing a consolidated return and consenting to be bound by Regulations 78. The trustee in bankruptcy of the Savoy-Plaza Corporation failed to file form 1122 because, upon advice of counsel, it believed it…

1Opinion of the Court

*541OPINION.

Leech:

These consolidated proceedings involve income tax deficiencies proposed by respondent for tlie calendar year 1932 against the petitioners, as follows:

Lawyers Building Corporation_ $3,406. 01

Trinity Buildings Corporation of New York_ 62, 491.15

Whitehall Improvement Corporation_ 20,335. 09

George A. Fuller Co_ 32, 249. 90

Materials Delivery Corporation_ 66.34

The facts, which were stipulated, are briefly as follows: The petitioners, during the taxable year, were 5 affiliates in a group of 15 affiliated companies whose parent was the United States Realty & Improvement Co., a New…

2Cases cited1 opinion

  1. Rock Island, Arkansas & Louisiana Railroad v. United StatesSupreme Court of the United States · 1920

3Cited by3 opinions

  1. Landy Towel & Linen Service, Inc. v. CommissionerUnited States Tax Court · 1962
  2. Landy Towel & Linen Service, Inc. v. CommissionerUnited States Tax Court · 1962
  3. Lawyers' Bldg. Corp. v. CommissionerUnited States Board of Tax Appeals · 1937

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