Beneficial Industrial Loan Corp. v. Commissioner
United States Tax Court
1. Petitioner and its 250 or more subsidiaries elected under section 730 of the Internal Revenue Code to file a consolidated excess profits tax return for the calendar year 1940. Most of the subsidiaries were small loan companies, which kept books and reported income on the basis of cash receipts and disbursements.
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1. Petitioner and its 250 or more subsidiaries elected under section 730 of the Internal Revenue Code to file a consolidated excess profits tax return for the calendar year 1940. Most of the subsidiaries were small loan companies, which kept books and reported income on the basis of cash receipts and disbursements. Two of the subsidiaries were insurance companies, which kept books and reported income on the accrual basis prescribed by section 204 of the Internal Revenue Code. During the base period years, as well as the taxable year, the insurance subsidiaries, in consideration of flat…
1Opinion of the Court
OPINION.
Arundell, Judge:
Petitioner and its 250 odd subsidiaries availed themselves of the privilege conferred by section 730 (a) of the code to file a consolidated excess profits tax return for the calendar year 1940. In so doing they were required by statute to consent to all of the regulations promulgated by respondent under section 730 (b) and in effect on the last day prescribed by law for filing the return.
One of the regulations adopted by the respondent pursuant to section 730 (b) of the code is section 33.44 (b) of Regulations 110, which reads as follows:
Sec. 33.44. Methods of…
2Cases cited2 opinions
- Boyd-Richardson Co. v. CommissionerUnited States Tax Court · 1945
- J.F. Johnson Lumber Co. v. CommissionerUnited States Tax Court · 1944
3Cited by3 opinions
- Great American Indem. Co. v. CommissionerUnited States Tax Court · 1952
- Beneficial Industrial Loan Corp. v. CommissionerUnited States Tax Court · 1946
- Great American Indem. Co. v. CommissionerUnited States Tax Court · 1952