Algernon Blair, Inc. v. Commissioner
United States Tax Court
1. Petitioner, a general contractor, filed a consolidated return for 1953 with two wholly owned subsidiaries, Forest Hills and Loxley Annex. Petitioner reported its income on the completed contract method. Under that method it accumulated its revenues and costs (which it considered attributable to a contract) and reported the difference as gross profit or loss in the year of completion of the contract.
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1. Petitioner, a general contractor, filed a consolidated return for 1953 with two wholly owned subsidiaries, Forest Hills and Loxley Annex. Petitioner reported its income on the completed contract method. Under that method it accumulated its revenues and costs (which it considered attributable to a contract) and reported the difference as gross profit or loss in the year of completion of the contract. It deducted the general expenses, which it did not consider attributable to any specific contract, currently, in the year in which incurred. During 1953, it completed nine contracts, including…
1Opinion of the Court
OPINION.
Black, Judge:
Tbe issues will be discussed in the same order as the findings of fact relating thereto.
Issue 1. Intereomfany Eliminations.
Petitioner, a general contractor, filed a consolidated return for the year 1953 with two wholly owned subsidiaries, Forest Hills and Loxley Annex. The first issue requires a determination of the amount of unrealized profit arising from intercompany transactions which should be eliminated in the computation of consolidated net income on that return.
During the year in question, petitioner, which reports on the completed contract basis, completed nine…
2Cases cited8 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Helvering v. TaylorSupreme Court of the United States · 1935
- Commissioner of Internal Revenue v. Union Pac. R. Co.Court of Appeals for the Second Circuit · 1936
- Acer Realty Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1942
- Clinton Cotton Mills v. Commissioner of Internal Rev.Court of Appeals for the Fourth Circuit · 1935
3 more not listed; retrieve them via the Exa API.
3Cited by27 opinions
- D. Loveman & Son Export Corp. v. CommissionerUnited States Tax Court · 1960
- Shainberg v. CommissionerUnited States Tax Court · 1959
- Southern Natural Gas Company v. The United StatesUnited States Court of Claims · 1969
- Parsons v. CommissionerUnited States Tax Court · 1964
- La Croix v. CommissionerUnited States Tax Court · 1974
22 more not listed; retrieve them via the Exa API.