Pennsylvania Co. for Ins. etc. v. Commissioner
United States Board of Tax Appeals
The effect of consolidation was to create a new corporation which is not entitled to deduct a net loss sustained by one of its predecessor corporations.
1Opinion of the Court
OPINION.
Arundell :
The respondent determined a deficiency in income for the fiscal year ended November 30,1929, in the amount of $46,307.14, of which $13,327.30 is in controversy. Two petitions have been filed and docketed based upon the one deficiency notice sent out by the *1286respondent. The name of the petitioner is the same in both. In one, Docket No. 64194, it is alleged that petitioner was incorporated under letters patent dated June 1,1929, and in the other, Docket No. 64196, petitioner alleges it is a corporation under letters patent issued in 1930. Counsel stipulated for the…
2Cases cited9 opinions
- Continental Insurance v. United StatesSupreme Court of the United States · 1922
- Pennsylvania Utilities Co. v. Public Service CommissionSuperior Court of Pennsylvania · 1918
- Athol Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1931
- Clark Dredging Co. v. CommissionerUnited States Board of Tax Appeals · 1931
- Overbrook Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1931
4 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- General Finance Co. v. CommissionerUnited States Board of Tax Appeals · 1935
- Pennsylvania Co. for Ins. etc. v. CommissionerUnited States Board of Tax Appeals · 1934