Legal Opinion

American Fork & Hoe Co. v. Commissioner

United States Board of Tax Appeals

Decided February 20, 1936No. Docket No. 60681Published

1. The petitioner, an Ohio corporation, owned, through two New York corporation, except qualifying shares. Held, that petitioner is not entitled to include the New York corporation in its consolidated return, following Commissioner v. Manus-Muller & Co., 79 Fed.(2d) 19; certiorari denied, 296 U.S. 657. 2. A taxpayer on the accrual basis can not be charged with income if there exists good reason for believing that the income can not be collected.

1Opinion of the Court

THE AMERICAN FORK & HOE COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

American Fork & Hoe Co. v. Commissioner

Docket No. 60681.

United States Board of Tax Appeals

33 B.T.A. 1139; 1936 BTA LEXIS 773;

February 20, 1936, Promulgated

1. The petitioner, an Ohio corporation, owned, through two New York corporation, except qualifying shares. Held, that petitioner is not entitled to include the New York corporation in its consolidated return, following Commissioner v. Manus-Muller & Co., 79 Fed.(2d) 19; certiorari denied, 296 U.S. 657.

2. A taxpayer on the accrual basis can not be…

2Cases cited2 opinions

  1. American Fork & Hoe Co. v. CommissionerUnited States Board of Tax Appeals · 1936
  2. Manus-Muller & Co. v. CommissionerUnited States Board of Tax Appeals · 1934

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