Legal Opinion

Industrial Loan Soc. v. Commissioner

United States Tax Court

Decided March 27, 1950No. Docket Nos. 9247, 16534Published

Net earnings of a business conducted during part of base period prior to petitioner's existence by a wholly owned affiliate, and of which the affiliate has obtained the benefit in computing its own credit for base period income, held insufficient by itself to demonstrate petitioner's right to relief from excess profits tax under section 722 (b) (4).

1Opinion of the Court

Industrial Loan Society, Inc., (Md.), Petitioner, v. Commissioner of Internal Revenue, Respondent

Industrial Loan Soc. v. Commissioner

Docket Nos. 9247, 16534

United States Tax Court

14 T.C. 487; 1950 U.S. Tax Ct. LEXIS 245;

March 27, 1950, Promulgated

Decision will be entered for the respondent.

Net earnings of a business conducted during part of base period prior to petitioner's existence by a wholly owned affiliate, and of which the affiliate has obtained the benefit in computing its own credit for base period income, held insufficient by itself to demonstrate petitioner's right to relief from…

Also in this document: Dissent.

2Cases cited6 opinions

  1. National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
  2. Stone v. WhiteSupreme Court of the United States · 1937
  3. Crocker v. MalleySupreme Court of the United States · 1919
  4. A. C. Burton & Co. v. CommissionerUnited States Tax Court · 1950
  5. George J. Meyer Malt & Grain Corp. v. CommissionerUnited States Tax Court · 1948

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