Remco Steamship Co. v. Commissioner
United States Board of Tax Appeals
1. Section 240(f) of the Revenue Act of 1926 contemplates the consolidation of all the accounts of several related companies. 2. A corporation received a dividend from a wholly owned subsidiary in a year in which it suffered heavy losses. Held, the amount of such dividend may not be excluded from the income of the recipient in the computation of net loss to be forwarded to a subsequent taxable year.
1Opinion of the Court
*581OPINION.
Lansdon :
The petitioners, at the hearing and on their brief, have abandoned their contention that Nedwood was affiliated with them for Federal tax purposes in the taxable years. As their first contention they now claim that a partial consolidation of their accounts with those of Nedwood for the years 1926,1927, and 1928 is necessary in order to determine the correct taxable income of each for such years. The effect of consolidation would be to increase the net loss of Caspar for 1926 and so reduce its tax liability for 1927, and at the same time decrease its operating income for' each…
2Cases cited7 opinions
- Woolford Realty Co. v. RoseSupreme Court of the United States · 1932
- Blair v. Oesterlein MacHine Co.Supreme Court of the United States · 1927
- Broadway Strand Theatre Co. v. CommissionerUnited States Board of Tax Appeals · 1928
- W. C. Mitchell Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Western Hide & Fur Co. v. CommissionerUnited States Board of Tax Appeals · 1932
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3Cited by4 opinions
- Estate of Gardner v. CommissionerUnited States Tax Court · 1984
- American Founders Corp. v. CommissionerUnited States Board of Tax Appeals · 1934
- Estate of Gardner v. CommissionerUnited States Tax Court · 1984
- Remco Steamship Co. v. CommissionerUnited States Board of Tax Appeals · 1934