Legal Opinion

Koppers Co. v. Commissioner

United States Tax Court

Decided November 30, 1948No. Docket No. 6232Published

Petitioner, as a member of an affiliated group of corporations which filed a consolidated return for the year 1930, under section 141 of the 1928 Revenue Act, was severally liable for the tax upon the consolidated income, including the deficiency. Upon determination in 1940 of a deficiency in the 1930 tax, the remaining members of the group, who were severally liable also, agreed upon their proportionate shares of the deficiency.

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Petitioner, as a member of an affiliated group of corporations which filed a consolidated return for the year 1930, under section 141 of the 1928 Revenue Act, was severally liable for the tax upon the consolidated income, including the deficiency. Upon determination in 1940 of a deficiency in the 1930 tax, the remaining members of the group, who were severally liable also, agreed upon their proportionate shares of the deficiency. Petitioner paid its share, thus agreed upon, and interest thereon. Held, that the interest was paid upon an obligation of the petitioner upon which there was no…

1Opinion of the Court

Koppers Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

Koppers Co. v. Commissioner

Docket No. 6232

United States Tax Court

11 T.C. 894; 1948 U.S. Tax Ct. LEXIS 21;

November 30, 1948, Promulgated

Decision will be entered under Rule 50.

Petitioner, as a member of an affiliated group of corporations which filed a consolidated return for the year 1930, under section 141 of the 1928 Revenue Act, was severally liable for the tax upon the consolidated income, including the deficiency. Upon determination in 1940 of a deficiency in the 1930 tax, the remaining members of the group, who…

2Cases cited4 opinions

  1. Phillips-Jones Corp. v. ParmleySupreme Court of the United States · 1937
  2. Koppers Co. v. CommissionerUnited States Tax Court · 1944
  3. Koppers Co. v. CommissionerUnited States Tax Court · 1947
  4. Koppers Co. v. CommissionerUnited States Tax Court · 1948

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