Riley Stoker Corp. v. Commissioner
United States Board of Tax Appeals
1. Where an affiliation occurs to break up a taxable year into shorter taxable periods, neither of which is taxpayer's first or last accounting period, such periods are not to be treated as separate "taxable years," but taxpayer's income is to be determined upon the basis of a twelve-month period. 2. A net loss sustained by a corporation prior to affiliation may be applied against its net income for the succeeding taxable year to the extent that it has not been absorbed by…
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1. Where an affiliation occurs to break up a taxable year into shorter taxable periods, neither of which is taxpayer's first or last accounting period, such periods are not to be treated as separate "taxable years," but taxpayer's income is to be determined upon the basis of a twelve-month period. 2. A net loss sustained by a corporation prior to affiliation may be applied against its net income for the succeeding taxable year to the extent that it has not been absorbed by the income of the consolidated group for the year in which the loss was sustained.
1Opinion of the Court
RILEY STOKER CORPORATION, FORMERLY NAMED SANFORD RILEY STOKER COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Riley Stoker Corp. v. Commissioner
Docket No. 36584.
United States Board of Tax Appeals
26 B.T.A. 749; 1932 BTA LEXIS 1253;
July 29, 1932, Promulgated
1. Where an affiliation occurs to break up a taxable year into shorter taxable periods, neither of which is taxpayer's first or last accounting period, such periods are not to be treated as separate "taxable years," but taxpayer's income is to be determined upon the basis of a twelve-month period.
2. A net loss sustained…
2Cases cited8 opinions
- Woolford Realty Co. v. RoseSupreme Court of the United States · 1932
- Planters Cotton Oil Co. v. HopkinsSupreme Court of the United States · 1932
- Delaware & Hudson Co. v. CommissionerUnited States Board of Tax Appeals · 1932
- General Box Corp. v. CommissionerUnited States Board of Tax Appeals · 1931
- Riley Stoker Corp. v. CommissionerUnited States Board of Tax Appeals · 1932
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