Bowman Hotel Corp. v. Commissioner
United States Board of Tax Appeals
1. Where a taxpayer corporation, incorporated under the laws of the State of New York, is consolidating with another corporation of the same State under the laws of the State of New York relating to the consolidation of corporations forming a new corporation, such new corporation is a proper party to prosecute an appeal from deficiency letters addressed to and mailed to such consolidating corporation for taxes incurred by it in years prior to the consolidation. 2.…
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1. Where a taxpayer corporation, incorporated under the laws of the State of New York, is consolidating with another corporation of the same State under the laws of the State of New York relating to the consolidation of corporations forming a new corporation, such new corporation is a proper party to prosecute an appeal from deficiency letters addressed to and mailed to such consolidating corporation for taxes incurred by it in years prior to the consolidation. 2. Capital-stock taxes accrued in 1926 but not paid until 1928 are properly deductible from 1926 income where the books of the…
1Opinion of the Court
*1201OPINION.
Black:
The issues involved in this proceeding have already been stated preliminary to our findings of fact. We will first dispose of the question of jurisdiction mentioned in paragraph (5) of our preliminary statement. In Docket Nos. 24912, 28917, and 38006 the appeals are taken in the name of “The Bowman-Biltmore Hotels Corporation, successor to Bowman Hotel Corporation.”
Paragraph (1) of each of said petitions alleges: “ The Bowman Hotel Corporation was incorporated April 16, 1916, under the laws of the State of New York and has its principal place of business at the Commodore Hotel,…
2Cases cited5 opinions
- LaBelle Iron Works v. United StatesSupreme Court of the United States · 1921
- Aluminum Castings Co. v. RoutzahnSupreme Court of the United States · 1930
- Guaranty Trust Co. v. New York & Queens County Railway Co.New York Court of Appeals · 1930
- Irvine v. . New York Edison Co.New York Court of Appeals · 1913
- Edison Electric Light Co. v. WestinghouseUnited States Circuit Court · 1888
3Cited by18 opinions
- Brannon's of Shawnee, Inc. v. CommissionerUnited States Tax Court · 1978
- Koppers Company v. United StatesUnited States Court of Claims · 1955
- Turnbull, Inc. v. CommissionerUnited States Tax Court · 1964
- Frelmort Realty Corp. v. CommissionerUnited States Board of Tax Appeals · 1933
- Popular Library, Inc. v. CommissionerUnited States Tax Court · 1963
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