Taylor-Wharton Iron & Steel Co. v. Commissioner

The consolidated income tax return filed ■by the parent of a group of affiliated corporations disclosed that certain of the affiliates had separately sustained losses which resulted in losses sustained by the group in 1924 *301and 1925. In 1926, the taxable year, the same affiliates again sustained losses; yet, after deducting them from profits made by other affiliates, the group made a gain. In determining the taxable gain, the petitioning taxpayer made an effort to carry forward as a unit and apply the consolidated net losses in .1.924 and 1925 against the consolidated net gain in 1926 without…