Legal Opinion

Pine Ridge Coal Co. v. Commissioner

United States Board of Tax Appeals

Decided May 29, 1931No. Docket Nos. 27337, 30228Published

1. The petitioner having filed separate returns for 1922 and 1923, is not entitled to have its tax computed for those years on a consolidated basis. 2. Advances to, and investment in capital stock of a corporation, held on the evidence to have been made by the petitioner, and since the corporation became bankrupt in 1922 without sufficient assets to pay unsecured creditors, of which petitioner was one, the amounts so advanced and invested were proper deductions from income…

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1. The petitioner having filed separate returns for 1922 and 1923, is not entitled to have its tax computed for those years on a consolidated basis. 2. Advances to, and investment in capital stock of a corporation, held on the evidence to have been made by the petitioner, and since the corporation became bankrupt in 1922 without sufficient assets to pay unsecured creditors, of which petitioner was one, the amounts so advanced and invested were proper deductions from income for the taxable year and the Commissioner erred in disallowing them.

1Opinion of the Court

PINE RIDGE COAL COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Pine Ridge Coal Co. v. Commissioner

Docket Nos. 27337, 30228.

United States Board of Tax Appeals

23 B.T.A. 489; 1931 BTA LEXIS 1865;

May 29, 1931, Promulgated

1. The petitioner having filed separate returns for 1922 and 1923, is not entitled to have its tax computed for those years on a consolidated basis.

2. Advances to, and investment in capital stock of a corporation, held on the evidence to have been made by the petitioner, and since the corporation became bankrupt in 1922 without sufficient assets to pay…

2Cases cited1 opinion

  1. Pine Ridge Coal Co. v. CommissionerUnited States Board of Tax Appeals · 1931

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