Industrial Cotton Mills Co. v. Commissioner
United States Board of Tax Appeals
One corporation owned all of the stock of another corporation during the first six months of the taxable year. At the end of that time the two corporations were consolidated or merged into one. Held, there was no affiliation during the last six months of the year, and one consolidated return for the entire year was not proper.
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One corporation owned all of the stock of another corporation during the first six months of the taxable year. At the end of that time the two corporations were consolidated or merged into one. Held, there was no affiliation during the last six months of the year, and one consolidated return for the entire year was not proper. A net loss of one of the companies for the preceding year may be deducted only from its net income for the first six months of the taxable year here in question.
1Opinion of the Court
INDUSTRIAL COTTON MILLS COMPANY, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Industrial Cotton Mills Co. v. Commissioner
Docket Nos. 28131, 28132.
United States Board of Tax Appeals
22 B.T.A. 648; 1931 BTA LEXIS 2090;
March 10, 1931, Promulgated
One corporation owned all of the stock of another corporation during the first six months of the taxable year. At the end of that time the two corporations were consolidated or merged into one. Held, there was no affiliation during the last six months of the year, and one consolidated return for the entire year was not proper. A net…
2Cases cited1 opinion
- Industrial Cotton Mills Co. v. CommissionerUnited States Board of Tax Appeals · 1931