Candy Bros. Mfg. Co. v. Commissioner
United States Tax Court
Petitioner from December 17, 1940, was a wholly owned subsidiary of its parent corporation. For 1941 the parent and subsidiaries, including petitioner, filed a consolidated excess profits tax return, using petitioner's net operating loss for 1941, but not its net operating loss for 1940. The year 1941 was the last consolidated return period for the consolidated group.
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Petitioner from December 17, 1940, was a wholly owned subsidiary of its parent corporation. For 1941 the parent and subsidiaries, including petitioner, filed a consolidated excess profits tax return, using petitioner's net operating loss for 1941, but not its net operating loss for 1940. The year 1941 was the last consolidated return period for the consolidated group. The Commissioner, in the deficiency notice here involved, for the years 1942 and 1943, denied to petitioner deduction of its net operating losses for 1940 and 1941, in the computation of surtax net income in computation of…
1Opinion of the Court
Candy Bros. Mfg. Co., Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent
Candy Bros. Mfg. Co. v. Commissioner
Docket No. 25692
United States Tax Court
17 T.C. 298; 1951 U.S. Tax Ct. LEXIS 98;
September 19, 1951, Promulgated
Decision will be entered for the respondent.
Petitioner from December 17, 1940, was a wholly owned subsidiary of its parent corporation. For 1941 the parent and subsidiaries, including petitioner, filed a consolidated excess profits tax return, using petitioner's net operating loss for 1941, but not its net operating loss for 1940. The year 1941 was the last…
2Cases cited6 opinions
- National Labor Relations Board v. Bailey Co. (East Side Branch)Court of Appeals for the Sixth Circuit · 1950
- Jorden v. CommissionerUnited States Tax Court · 1948
- Sokol Bros. Furniture Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1950
- Basalt Rock Co. v. CommissionerUnited States Tax Court · 1948
- Doylestown & Easton Motor Coach Co. v. CommissionerUnited States Tax Court · 1947
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