General Mfg. Corp. v. Commissioner
United States Tax Court
Held, that petitioner was not entitled to file a consolidated return with its parent corporation for the taxable year ended October 31, 1957, because it did not make a timely consent to the filing of a consolidated return and the parent corporation, which for prior years filed its return on a calendar year basis, did not obtain approval of Commissioner to change to a fiscal year basis for reporting income.
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Held, that petitioner was not entitled to file a consolidated return with its parent corporation for the taxable year ended October 31, 1957, because it did not make a timely consent to the filing of a consolidated return and the parent corporation, which for prior years filed its return on a calendar year basis, did not obtain approval of Commissioner to change to a fiscal year basis for reporting income. Held, further, that the consolidated return, which was filed in good faith and disclosed items of income and deductions of petitioner necessary for computation of tax, constituted the…
1Opinion of the Court
Dawson, Judge:
Respondent determined a deficiency of $43,939.04 in the income tax of petitioner for the taxable year ended October 31, 1957. The issues presented for decision are: (1) Whether petitioner, General Manufacturing Corp., and its parent, B. B. Rider Corp., filed a consolidated corporation income tax return for the taxable year ended October 31,1957; (2) whether the notice of deficiency dated 'September 5,1963, was timely issued or was barred by applicable limitation provisions of the Internal Revenue Code; (3) whether petitioner is entitled to a bad debt deduction in the amount of…
2Cases cited13 opinions
- Commissioner v. Lane-Wells Co.Supreme Court of the United States · 1944
- Zellerbach Paper Co. v. HelveringSupreme Court of the United States · 1934
- Germantown Trust Co. v. CommissionerSupreme Court of the United States · 1940
- Burford Oil Co. v. CommissionerUnited States Tax Court · 1945
- Burford Oil Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1946
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3Cited by7 opinions
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- Millette & Associates, Inc. v. CommissionerUnited States Tax Court · 1978
- General Mfg. Corp. v. CommissionerUnited States Tax Court · 1965
- Intervest Enterprises, Inc. v. CommissionerUnited States Tax Court · 1972
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