Houghton & Dutton Co. v. Commissioner
United States Board of Tax Appeals
1. Where petitioner's wholly owned subsidiary was insolvent and discontinued business on the last day of the year, resulting in allowable deductions to petitioner for losses, bad debts, and accrued expenses, the deductions may be taken against petitioner's income for the year and are not limited to the income for the period between the close of business on the last day of the year and the end of the year.
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1. Where petitioner's wholly owned subsidiary was insolvent and discontinued business on the last day of the year, resulting in allowable deductions to petitioner for losses, bad debts, and accrued expenses, the deductions may be taken against petitioner's income for the year and are not limited to the income for the period between the close of business on the last day of the year and the end of the year. Canal-Commercial National Bank,22 B.T.A. 541, not followed. 2. The amount of the deductions is to be adjusted on account of operating losses sustained within the year and reflected in…
1Opinion of the Court
HOUGHTON & DUTTON COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Houghton & Dutton Co. v. Commissioner
Docket No. 24883.
United States Board of Tax Appeals
26 B.T.A. 1420; 1932 BTA LEXIS 1150;
October 31, 1932, Promulgated
1. Where petitioner's wholly owned subsidiary was insolvent and discontinued business on the last day of the year, resulting in allowable deductions to petitioner for losses, bad debts, and accrued expenses, the deductions may be taken against petitioner's income for the year and are not limited to the income for the period between the close of business on…
2Cases cited9 opinions
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- Woolford Realty Co. v. RoseSupreme Court of the United States · 1932
- Burnet v. Thompson Oil & Gas Co.Supreme Court of the United States · 1931
- Riggs Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1929
- Houghton & D. Co. v. CommissionerUnited States Board of Tax Appeals · 1932
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