Simms Petroleum Co. v. Commissioner
United States Board of Tax Appeals
1. Losses allowable on account of the abandonment or other disposition of oil leases determined. 2. A net loss sustained by a member of an affiliated group in 1923 may not be carried forward under the provisions of section 206 of the Revenue Act of 1926 and allowed as a deduction in computing consolidated net income in 1925 where the corporation which sustained the net loss in 1923 had no net income in 1925. 3. A liquidation in kind held not to have occurred through an…
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1. Losses allowable on account of the abandonment or other disposition of oil leases determined. 2. A net loss sustained by a member of an affiliated group in 1923 may not be carried forward under the provisions of section 206 of the Revenue Act of 1926 and allowed as a deduction in computing consolidated net income in 1925 where the corporation which sustained the net loss in 1923 had no net income in 1925. 3. A liquidation in kind held not to have occurred through an agreement between a majority of the stockholders of a corporation and a purchaser of such stock wherein it ws agreed that any…
1Opinion of the Court
SIMMS PETROLEUM COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
SIMMS OIL COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
TRINITY DRILLING COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Simms Petroleum Co. v. Commissioner
Docket Nos. 61496-61498.
United States Board of Tax Appeals
28 B.T.A. 1107; 1933 BTA LEXIS 1052;
August 15, 1933, Promulgated
1. Losses allowable on account of the abandonment or other disposition of oil leases determined.
2. A net loss sustained by a member of an affiliated group in 1923 may not be carried forward…
2Cases cited2 opinions
- Petroleum Exploration v. BurnetSupreme Court of the United States · 1933
- Simms Petroleum Co. v. CommissionerUnited States Board of Tax Appeals · 1933