Woolford Realty Co. v. Rose

HUTCHESON, Circuit Judge.

In 1925 the'Piedmont Savings Company sustained a statutory net loss of $43,478.25; in 1926 it sustained a further statutory net loss of $410.82; it was in those years unaffiliated. . In 1927, appellant and the Piedmont Savings Company having become affiliated, a consolidated return for that year was filed. This return disclosed a combined net income for that year of $37,128.83 made up. of appellant’s net taxable, income of $37,-582.63 and a loss of Piedmont, $453.80. The Commissioner, because Piedmont had no net income in 1927, refused to allow appellant to deduct…