Imperial Assurance Co. v. Commissioner
United States Board of Tax Appeals
AFFILIATION - RETURNS - ELECTION. - Where four corporations were affiliated during the taxable year 1922 and filed separate returns, and the same four corporations were affiliated during the year 1923 with two others, they can not file a consolidated return for 1923 without the permission of the Commissioner.
1Opinion of the Court
*1070OPINION.
Black:
Section 240 (a) of the Revenue Act of 1921 is as follows:
Seo. 240. (a) That corporations which are affiliated within the meaning of this section may, for any taxable year beginning on or after January 1, 1922, make separate returns or, under regulations prescribed by the Commissioner with the approval of the Secretary, make a consolidated return of net income for the purpose of this title, in which case the taxes thereunder shall be computed and determined upon the basis of such return. If return is made on either of such bases, all returns thereafter made shall be upon the same…
2Cited by8 opinions
- Albert Leon & Son, Inc. v. CommissionerUnited States Board of Tax Appeals · 1933
- Huntington Beach, Inc. v. CommissionerUnited States Board of Tax Appeals · 1934
- Peerless Pattern Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Whitman, Ward & Lee Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Braden Steel Corp. v. CommissionerUnited States Board of Tax Appeals · 1934
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