Houghton & Dutton Co. v. Commissioner
United States Board of Tax Appeals
1. Where petitioner's wholly owned subsidiary was insolvent and discontinued business on the last day of the year, resulting in allowable deductions to petitioner for losses, bad debts, and accrued expenses, the deductions may be taken against petitioner's income for the year and are not limited to the income for the period between the close of business on the last day of the year and the end of the year.
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1. Where petitioner's wholly owned subsidiary was insolvent and discontinued business on the last day of the year, resulting in allowable deductions to petitioner for losses, bad debts, and accrued expenses, the deductions may be taken against petitioner's income for the year and are not limited to the income for the period between the close of business on the last day of the year and the end of the year. Canal-Commercial National Bank,22 B.T.A. 541, not followed. 2. The amount of the deductions is to be adjusted on account of operating losses sustained within the year and reflected in…
1Opinion of the Court
OPINION.
Ahundell:
This proceeding involves income and profits taxes for the years 1919 and 1920. At the hearing on the merits the issues relating to 1919 were disposed of by the parties by waiver and *1421stipulation, but the matter oí recomputation for that year was left open. We decided the issues concerning 1920 in our report promulgated at 26 B. T. A. 52. Upon recomputation it developed that there was a slight difference between the parties concerning minor adjustments to inadmissible assets for invested capital purposes, but as to these counsel for petitioner recedes, and the respondent’s…
2Cases cited3 opinions
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- Woolford Realty Co. v. RoseSupreme Court of the United States · 1932
- Burnet v. Thompson Oil & Gas Co.Supreme Court of the United States · 1931
3Cited by6 opinions
- W. M. Ritter Lumber Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Cerro De Pasco Copper Corp. v. United StatesUnited States Court of Claims · 1936
- Sprague-Sells Corp. v. CommissionerUnited States Board of Tax Appeals · 1934
- Houghton & Dutton Co. v. CommissionerUnited States Board of Tax Appeals · 1932
- Stutz Motor Car Co. of America v. United StatesDistrict Court, S.D. Indiana · 1936
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