Post & Sheldon Corp. v. Commissioner
United States Board of Tax Appeals
In computing consolidated net income for 1928 of affiliated corporations having prior net losses, intercompany transactions which in any way effect the total net income or the separate net income or apportioned tax of any memebr must be eliminated.
1Opinion of the Court
OPINION.
Sternhagen :
The petitioner is one of two affiliated corporations, which, year return. Upon the basis of such consolidated return, the Commissioner determined a deficiency in petitioner’s income tax of $700.06. The petitioner assails this upon the ground that in computing consolidated net income the Commissioner has failed to eliminate two intercompany items, the result of which failure is to distort consolidated net income and effect an excessive tax. The facts appear entirely in an agreed statement.
The petitioner and the National Warping & Winding Co. were continuously affiliated…
2Cases cited3 opinions
- Woolford Realty Co. v. RoseSupreme Court of the United States · 1932
- Planters Cotton Oil Co. v. HopkinsSupreme Court of the United States · 1932
- Delaware & Hudson Co. v. CommissionerUnited States Board of Tax Appeals · 1932
3Cited by4 opinions
- New York, O. & W. R. Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Autocar Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Pierce Oil Corp. v. CommissionerUnited States Board of Tax Appeals · 1935
- Post & Sheldon Corp. v. CommissionerUnited States Board of Tax Appeals · 1933