Legal Opinion

Automobile Loans, Inc. v. Commissioner

United States Board of Tax Appeals

Decided November 4, 1937No. Docket No. 88173Published

The petitioner, a personal holding company, filed the prescribed return for surtax on such corporation, after March 15, but within an extension of time allowed. The shareholders of the petitioner corporation filed their returns March 15 without reporting in gross income their pro rata shares of petitioner's adjusted net income.

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The petitioner, a personal holding company, filed the prescribed return for surtax on such corporation, after March 15, but within an extension of time allowed. The shareholders of the petitioner corporation filed their returns March 15 without reporting in gross income their pro rata shares of petitioner's adjusted net income. Later, at the time petitioner filed its surtax return, the shareholders filed "amended returns" reporting gross income so as to include their pro rata shares of petitioner's adjusted net income. Held that "the time a filing their retrns" was when the first returns were…

1Opinion of the Court

AUTOMOBILE LOANS, INCORPORATED, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Automobile Loans, Inc. v. Commissioner

Docket No. 88173.

United States Board of Tax Appeals

36 B.T.A. 809; 1937 BTA LEXIS 650;

November 4, 1937, Promulgated

The petitioner, a personal holding company, filed the prescribed return for surtax on such corporation, after March 15, but within an extension of time allowed. The shareholders of the petitioner corporation filed their returns March 15 without reporting in gross income their pro rata shares of petitioner's adjusted net income. Later, at the time…

2Cases cited3 opinions

  1. Downes v. CommissionerUnited States Board of Tax Appeals · 1927
  2. Automobile Loans, Inc. v. CommissionerUnited States Board of Tax Appeals · 1937
  3. Johnston v. CommissionerUnited States Board of Tax Appeals · 1935

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