National Piano Manufacturing Co. v. Commissioner

*55OPINION.

Siepkin :

This proceeding raises questions as to—

1. Whether assessment and collection of taxes for the year 1917 are barred by the statute of limitations;

*562. The inclusion of income of the petitioner’s predecessor in the petitioner’s income for the year 1917;

3. Affiliation of petitioner and the Sparta Manufacturing Co.;

4. liespondent’s failure to deduct from taxable income in 1922 and |.923 an alleged net operating loss sustained by petitioner in 1921;

I 5. The deduction from income of petitioner of $22,948.76, which fcvas the amount of income tax of the National Automatic Music Co. Tor…