Daron Industries, Inc. v. Commissioner
United States Tax Court
1. T corporation and its newly formed or acquired subsidiaries filed a consolidated income tax return for 1964, reporting substantial consolidated taxable income, 6 days after the due date as extended. Consolidated returns for subsequent years filed by T reported considerable losses.
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1. T corporation and its newly formed or acquired subsidiaries filed a consolidated income tax return for 1964, reporting substantial consolidated taxable income, 6 days after the due date as extended. Consolidated returns for subsequent years filed by T reported considerable losses. Held, in the circumstances of this case, the 1964 return was a valid consolidated return such that consolidated losses of later years may be carried back to the consolidated income of 1964. 2. T filed a separate income tax return for 1963 which reported considerable taxable income and which was prior to the…
1Opinion of the Court
OPINION
Naum, Judge:
The Commissioner determined income tax deficiencies against petitioners as follows:
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In or around June or July of 1964 petitioner Daron Industries, Inc. (Daron), organized a number of subsidiary corporations which joined with it in. filing a consolidated, corporation income tax return for the calendar year 1904. This return was filed 6 days after its due date, including extensions of time granted by the Commissioner. Prior to 1964 Daron had filed separate corporation income tax returns. Although the 1964 return reported substantial taxable income, subsequent…
2Cases cited13 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Williamsport Wire Rope Co. v. United StatesSupreme Court of the United States · 1928
- Logan Lumber Company v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1966
- Rosano v. CommissionerUnited States Tax Court · 1966
- Trinco Industries, Inc. v. CommissionerUnited States Tax Court · 1954
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3Cited by4 opinions
- Millette & Associates, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1979
- Sellers v. CommissionerUnited States Tax Court · 1977
- Millette & Associates, Inc. v. CommissionerUnited States Tax Court · 1978
- Daron Industries, Inc. v. CommissionerUnited States Tax Court · 1974