Legal Opinion

American Textile Woolen Co. v. Commissioner

United States Board of Tax Appeals

Decided June 12, 1931No. Docket Nos. 9689, 20921Published

1. Petition in Docket No. 9689 dismissed as to the subsidiary corporations against which no deficiencies have been asserted. 2. Article 78 of Regulations 41, as amended by T.D. 3889, providing that consolidated profits taxes for the year 1917 may be allocated by members of an affiliated group as may be agreed among them or that in the absence of such an agreement the tax will be assessed upon each corporation in accordance with the net income and invested capital properly…

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1. Petition in Docket No. 9689 dismissed as to the subsidiary corporations against which no deficiencies have been asserted. 2. Article 78 of Regulations 41, as amended by T.D. 3889, providing that consolidated profits taxes for the year 1917 may be allocated by members of an affiliated group as may be agreed among them or that in the absence of such an agreement the tax will be assessed upon each corporation in accordance with the net income and invested capital properly assignable to it, approved. 3. The respondent's determination that an agreement existed among the members of its…

1Opinion of the Court

AMERICAN TEXTILE WOOLEN COMPANY ET AL., 1 PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

AMERICAN TEXTILE WOOLEN COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

American Textile Woolen Co. v. Commissioner

Docket Nos. 9689, 20921.

United States Board of Tax Appeals

23 B.T.A. 670; 1931 BTA LEXIS 1837;

June 12, 1931, Promulgated

1. Petition in Docket No. 9689 dismissed as to the subsidiary corporations against which no deficiencies have been asserted.

2. Article 78 of Regulations 41, as amended by T.D. 3889, providing that consolidated profits taxes for the year 1917…

2Cases cited9 opinions

  1. In re Temtor Corn & Fruit Products Co.District Court, E.D. Missouri · 1924
  2. Chicago, M. & ST. P. RY. CO. v. SchendelCourt of Appeals for the Eighth Circuit · 1923
  3. Woodside Cotton Mills Co. v. CommissionerUnited States Board of Tax Appeals · 1928
  4. American Creosoting Co. v. CommissionerUnited States Board of Tax Appeals · 1928
  5. Ohio & Big Sandy Coal Co. v. CommissionerUnited States Board of Tax Appeals · 1929

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