Legal Opinion

Brownsville Ice & Storage Co. v. Commissioner

United States Board of Tax Appeals

Decided December 6, 1929No. Docket No. 28897PublishedCited by 7 opinions

The petitioner was affiliated with the Brownsville Brewing Co. in the year 1922, and having filed a separate return for that year, the Commissioner did not err in determining its tax liability on the same basis for the taxable year.

1Opinion of the Court

*440OPINION.

Akundell :

The only issue before us for decision is whether the respondent erred in refusing to determine the petitioner’s income-*441tax liability in 1923 on the basis of a consolidated return. All other assignments of error were abandoned by the petitioner at the hearing.

The petitioner contends that it was not affiliated with the Brownsville Brewing Co. in 1922, and accordingly, the filing of a separate return in that year does not preclude it from filing a consolidated return for the year 1923, during which it was affiliated. The respondent, on the other hand, contends that it was…

2Cited by7 opinions

  1. W. M. Ritter Lumber Co. v. CommissionerUnited States Board of Tax Appeals · 1934
  2. Peerless Pattern Co. v. CommissionerUnited States Board of Tax Appeals · 1934
  3. Columbia Pac. Shipping Co. v. CommissionerUnited States Board of Tax Appeals · 1934
  4. Brownsville Ice & Storage Co. v. CommissionerUnited States Board of Tax Appeals · 1929
  5. Columbia Pacific Shipping Co. v. CommissionerUnited States Board of Tax Appeals · 1934

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