Legal Opinion

Daron Industries, Inc. v. Commissioner

United States Tax Court

Decided September 24, 1974No. Docket Nos. 2647-71, 2648-71, 2649-71, 2650-71, 2651-71, 2652-71Published

1. T corporation and its newly formed or acquired subsidiaries filed a consolidated income tax return for 1964, reporting substantial consolidated taxable income, 6 days after the due date as extended. Consolidated returns for subsequent years filed by T reported considerable losses.

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1. T corporation and its newly formed or acquired subsidiaries filed a consolidated income tax return for 1964, reporting substantial consolidated taxable income, 6 days after the due date as extended. Consolidated returns for subsequent years filed by T reported considerable losses. Held, in the circumstances of this case, the 1964 return was a valid consolidated return such that consolidated losses of later years may be carried back to the consolidated income of 1964. 2. T filed a separate income tax return for 1963 which reported considerable taxable income and which was prior to the…

1Opinion of the Court

Daron Industries, Inc., Formerly Airequipt, Inc., et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent

Daron Industries, Inc. v. Commissioner

Docket Nos. 2647-71, 2648-71, 2649-71, 2650-71, 2651-71, 2652-71

United States Tax Court

62 T.C. 847; 1974 U.S. Tax Ct. LEXIS 40; 62 T.C. No. 91;

September 24, 1974, Filed

Decisions will be entered under Rule 155.

1. T corporation and its newly formed or acquired subsidiaries filed a consolidated income tax return for 1964, reporting substantial consolidated taxable income, 6 days after the due date as extended. Consolidated returns for…

2Cases cited14 opinions

  1. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  2. Williamsport Wire Rope Co. v. United StatesSupreme Court of the United States · 1928
  3. Logan Lumber Company v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1966
  4. Rosano v. CommissionerUnited States Tax Court · 1966
  5. Trinco Industries, Inc. v. CommissionerUnited States Tax Court · 1954

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