Legal Opinion
Patent Royalties Corp. v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided June 12, 1933No. 244PublishedCited by 5 opinions
1Opinion of the Court
SWAN, Circuit Judge.
Patent Royalties Corporation and Holed-Tite Packing, Inc., were affiliated throughout the year 1927. Section 240 (a) of the Revenue Act of 1926 (44 Stat. 46), 26 USCA § 993 (a), permits affiliated corporations to make separate returns, or, under regulations prescribed by the Commissioner, to make a consolidated return. It further provides:
“If return is made on either of such bases, all returns thereafter made shall be upon the same basis unless permission to change the basis is granted by the commissioner.”
The question presented by this appeal is whether, under the faets…
2Cases cited6 opinions
- Rose v. GrantCourt of Appeals for the Fifth Circuit · 1930
- Alameda Inv. Co. v. McLaughlinCourt of Appeals for the Ninth Circuit · 1929
- Lucas v. Sterling Oil & Gas Co.Court of Appeals for the Sixth Circuit · 1933
- Morrow, Becker & Ewing, Inc. v. CommissionerCourt of Appeals for the Fifth Circuit · 1932
- Lucas v. St. Louis National Baseball ClubCourt of Appeals for the Eighth Circuit · 1930
1 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Meyer's Estate v. Commissioner of Internal Revenue. (Three Cases)Court of Appeals for the Fifth Circuit · 1952
- United States v. G. W. Van Keppel and Elizabeth Van KeppelCourt of Appeals for the Tenth Circuit · 1963
- Richardson v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1942
- Dr. Pepper Bottling Co. v. CommissionerCourt of Appeals for the Fifth Circuit · 1934
- Hall v. Comm'rUnited States Tax Court · 1991