Legal Opinion

Pittsburgh & W. Va. Ry. v. Commissioner

United States Board of Tax Appeals

Decided February 14, 1935No. Docket Nos. 72157, 72158Published

1. TAXABLE PERIODS FOR INCOME TAX UNDER REVENUE ACTS OF 1916 AND 1917, AND WAR EXCESS PROFITS TAX UNDER REVENUE ACT OF 1917. - Where a corporation was in existence during the entire calendar year 1917, but was a member of an affiliated group for the first three months of such year, and a member of another affiliated group with a different parent company for the last nine months of such year, held, that its taxable period for income tax purposes is the calendar year 1917, and…

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1. TAXABLE PERIODS FOR INCOME TAX UNDER REVENUE ACTS OF 1916 AND 1917, AND WAR EXCESS PROFITS TAX UNDER REVENUE ACT OF 1917. - Where a corporation was in existence during the entire calendar year 1917, but was a member of an affiliated group for the first three months of such year, and a member of another affiliated group with a different parent company for the last nine months of such year, held, that its taxable period for income tax purposes is the calendar year 1917, and its taxable periods for was excess profits tax purposes are the three and nine-month periods, respectively. Trustees…

1Opinion of the Court

THE PITTSBURGH & WEST VIRGINIA RAILWAY COMPANY, AS SUCCESSOR TO WEST SIDE BELT RAILROAD COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

THE PITTSBURGH & WEST VIRGINIA RAILWAY COMPANY, AS SUCCESSOR TO WABASH-PITTSBURGH TERMINAL RAILWAY COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Pittsburgh & W. Va. Ry. v. Commissioner

Docket Nos. 72157, 72158.

United States Board of Tax Appeals

32 B.T.A. 66; 1935 BTA LEXIS 1005;

February 14, 1935, Promulgated

1. TAXABLE PERIODS FOR INCOME TAX UNDER REVENUE ACTS OF 1916 AND 1917, AND WAR EXCESS PROFITS TAX UNDER REVENUE…

2Cases cited11 opinions

  1. Burnet v. Aluminum Goods Manufacturing Co.Supreme Court of the United States · 1933
  2. Bankers' Trust Co. v. BowersCourt of Appeals for the Second Circuit · 1923
  3. Smith v. CommissionerUnited States Board of Tax Appeals · 1932
  4. Elgin Compress Co. v. CommissionerUnited States Board of Tax Appeals · 1934
  5. Pittsburgh & W. Va. Ry. v. CommissionerUnited States Board of Tax Appeals · 1935

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