Acorn Refining Co. v. Commissioner
United States Board of Tax Appeals
1. NET LOSSES. - Petitioner acquired all the stock of eight corporations and they became affiliated in October 1929. Thereafter a consolidated return was filed. In computing the consolidated net income of the affiliated group for the taxable year, net losses of one subsidiary for two preceding years were deducted.
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1. NET LOSSES. - Petitioner acquired all the stock of eight corporations and they became affiliated in October 1929. Thereafter a consolidated return was filed. In computing the consolidated net income of the affiliated group for the taxable year, net losses of one subsidiary for two preceding years were deducted. Held, that the amount of the net losses of the subsidiary which may be deducted in computing consolidated net income is limited to the cost or aggregate basis of the stock of the subsidiary to the parent. Held, further, that article 41(c) of Regulations 75, providing for this…
1Opinion of the Court
THE ACORN REFINING COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Acorn Refining Co. v. Commissioner
Docket No. 74959.
United States Board of Tax Appeals
34 B.T.A. 566; 1936 BTA LEXIS 682;
May 12, 1936, Promulgated
1. NET LOSSES. - Petitioner acquired all the stock of eight corporations and they became affiliated in October 1929. Thereafter a consolidated return was filed. In computing the consolidated net income of the affiliated group for the taxable year, net losses of one subsidiary for two preceding years were deducted. Held, that the amount of the net losses of the…
2Cases cited1 opinion
- Acorn Refining Co. v. CommissionerUnited States Board of Tax Appeals · 1936