Legal Opinion

Western Hide & Fur Co. v. Commissioner

United States Board of Tax Appeals

Decided June 9, 1932No. Docket No. 44294Published

A taxpayer invoking the provisions of section 240(d) of the Revenue Act of 1924, and section 240(f) of the Revenue Act of 1926, for the consolidation of its accounts with those of another corporation must show the necessity for the consolidation and a method of "accurate distribution or apportionment" of the income and expenses of the two companies engaged in related trades or businesses and owned or controlled by the same interests.

1Opinion of the Court

WESTERN HIDE & FUR COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Western Hide & Fur Co. v. Commissioner

Docket No. 44294.

United States Board of Tax Appeals

26 B.T.A. 354; 1932 BTA LEXIS 1326;

June 9, 1932, Promulgated

A taxpayer invoking the provisions of section 240(d) of the Revenue Act of 1924, and section 240(f) of the Revenue Act of 1926, for the consolidation of its accounts with those of another corporation must show the necessity for the consolidation and a method of "accurate distribution or apportionment" of the income and expenses of the two companies engaged in…

2Cases cited4 opinions

  1. Broadway Strand Theatre Co. v. CommissionerUnited States Board of Tax Appeals · 1928
  2. Western Hide & Fur Co. v. CommissionerUnited States Board of Tax Appeals · 1932
  3. Nowland Realty Co. v. CommissionerUnited States Board of Tax Appeals · 1929
  4. Roessler & Hasslacher Chemical Co. v. CommissionerUnited States Board of Tax Appeals · 1932

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