Legal Opinion

General Finance Co. v. Commissioner

United States Board of Tax Appeals

Decided July 16, 1935No. Docket No. 76539Published

The petitioner is a Pennsylvania corporation, chartered January 20, 1930. It is the domestication under the laws of the Commonwealth of Pennsylvania of a corporation by the same name chartered by the State of Delaware August 31, 1921. The Delaware corporation had net losses for the years 1928 and 1929 which the petitioner seeks to deduct from gross income in computing its tax liability of 1930. Held, that the net losses of the Delaware corporation are not legal deductions…

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The petitioner is a Pennsylvania corporation, chartered January 20, 1930. It is the domestication under the laws of the Commonwealth of Pennsylvania of a corporation by the same name chartered by the State of Delaware August 31, 1921. The Delaware corporation had net losses for the years 1928 and 1929 which the petitioner seeks to deduct from gross income in computing its tax liability of 1930. Held, that the net losses of the Delaware corporation are not legal deductions from the income of the petitioner for 1930.

1Opinion of the Court

GENERAL FINANCE COMPANY OF PHILADELPHIA, PA., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

General Finance Co. v. Commissioner

Docket No. 76539.

United States Board of Tax Appeals

32 B.T.A. 949; 1935 BTA LEXIS 867;

July 16, 1935, Promulgated

The petitioner is a Pennsylvania corporation, chartered January 20, 1930. It is the domestication under the laws of the Commonwealth of Pennsylvania of a corporation by the same name chartered by the State of Delaware August 31, 1921. The Delaware corporation had net losses for the years 1928 and 1929 which the petitioner seeks to deduct from…

2Cases cited26 opinions

  1. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  2. Eisner v. MacOmberSupreme Court of the United States · 1920
  3. Towne v. EisnerSupreme Court of the United States · 1918
  4. Railway Co. v. Whitton's AdministratorSupreme Court of the United States · 1872
  5. Railroad Company v. HarrisSupreme Court of the United States · 1871

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