Morris County Crushed Stone Co. v. Commissioner
United States Board of Tax Appeals
Single consolidated income and profits-tax returns, Forms 1031 and 1103, filed for the calendar year 1917 by a corporation claiming to be affiliated with certain other corporations among which were the petitioners, which returns were signed and sworn to by the president and the secretary and treasurer of the alleged parent corporation, who were also similar officers of the alleged subsidiary corporations, and in which returns the consolidated income and invested capital of…
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Single consolidated income and profits-tax returns, Forms 1031 and 1103, filed for the calendar year 1917 by a corporation claiming to be affiliated with certain other corporations among which were the petitioners, which returns were signed and sworn to by the president and the secretary and treasurer of the alleged parent corporation, who were also similar officers of the alleged subsidiary corporations, and in which returns the consolidated income and invested capital of the several corporations were stated and to the excess-profits-tax return a consolidated balance sheet at the beginning…
1Opinion of the Court
*806OPINION.
Littleton:
The petitioners claim that the consolidated income and excess-profits-tax returns, Forms 1031 and 1103, constituted the return of each of them and that the statute of limitations began to run on the date these consolidated returns were filed on • March 30, 1918, and that since the Commissioner has not assessed any additional tax against them and did not make his determinations of the alleged deficiencies until 7 years and 5 months after March 30, 1918, their liability for any additional tax is extinguished by section 1106 of the Revenue Act of 1926.
The Commissioner contends…
2Cases cited1 opinion
- Beam v. HamiltonCourt of Appeals for the Sixth Circuit · 1923
3Cited by3 opinions
- American Textile Woolen Co. v. CommissionerUnited States Board of Tax Appeals · 1931
- Morris County Crushed Stone Co. v. CommissionerUnited States Board of Tax Appeals · 1927
- Stetson & Ellison v. CommissionerUnited States Board of Tax Appeals · 1928