Manus-Muller & Co. v. Commissioner
United States Board of Tax Appeals
1. Where a foreign corporation owns all of the stock of two domestic corporations, the three corporations constitute an "affiliated group" within the definition of that term in section 141(d), Revenue Act of 1928, and the two domestic corporations have the privilege of making a consolidated return for the calendar year 1929. 2. The provision of section 238 that a foreign corporation shall not be "deemed to be affiliated with any other corporation" within the meaning of…
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1. Where a foreign corporation owns all of the stock of two domestic corporations, the three corporations constitute an "affiliated group" within the definition of that term in section 141(d), Revenue Act of 1928, and the two domestic corporations have the privilege of making a consolidated return for the calendar year 1929. 2. The provision of section 238 that a foreign corporation shall not be "deemed to be affiliated with any other corporation" within the meaning of section 141, does not exclude foreign corporations from an affiliated group, but merely precludes them from joining in a…
1Opinion of the Court
MANUS-MULLER & CO., INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Manus-Muller & Co. v. Commissioner
Docket No. 59778.
United States Board of Tax Appeals
30 B.T.A. 1015; 1934 BTA LEXIS 1231;
June 26, 1934, Promulgated
1. Where a foreign corporation owns all of the stock of two domestic corporations, the three corporations constitute an "affiliated group" within the definition of that term in section 141(d), Revenue Act of 1928, and the two domestic corporations have the privilege of making a consolidated return for the calendar year 1929.
2. The provision of section 238 that a…
2Cases cited12 opinions
- Brewster v. GageSupreme Court of the United States · 1930
- Utah Power & Light Co. v. United StatesSupreme Court of the United States · 1917
- Fawcus MacHine Co. v. United StatesSupreme Court of the United States · 1931
- Morrill v. JonesSupreme Court of the United States · 1883
- Merritt v. CameronSupreme Court of the United States · 1890
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