Consolidated Industries, Inc. v. Commissioner
United States Tax Court
Connecticut taxes corporations pursuant to a "piggy-back" system whereby Federal taxable income serves as the State taxable income base. The Commissioner and Consolidated (a Connecticut corporation and an accrual method taxpayer) reached an agreement in 1983 that part of Consolidated's 1976 Federal deduction for officers' salaries should be disallowed.
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Connecticut taxes corporations pursuant to a "piggy-back" system whereby Federal taxable income serves as the State taxable income base. The Commissioner and Consolidated (a Connecticut corporation and an accrual method taxpayer) reached an agreement in 1983 that part of Consolidated's 1976 Federal deduction for officers' salaries should be disallowed. The resulting increase in Consolidated's 1976 Federal taxable income from the 1983 settlement gave rise to an additional Connecticut corporation business tax liability, which Consolidated sought to accrue in 1976. Held, Consolidated may not…
1Opinion of the Court
OPINION
Nims, Judge:
In these consolidated cases, respondent determined deficiencies in petitioners’ Federal income tax as follows:
Docket No. Petitioner Year Deficiency
20523-80 Consolidated Industries, Inc. 1975 $276,334
20524-80 Joseph C. Valentine and Shirley R. Valentine 1975 1976 11,865 613,722
20526-80 Ronald J. Clayton and Jane H. Clayton 1976 293,561
After concessions, the issue remaining for decision is whether an accrual method corporate taxpayer may deduct in 1976 additional State tax due for 1976 as a result of a 1983 adjustment to its 1976 Federal taxable income.
All of the facts have…
2Cases cited13 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
- United States v. Consolidated Edison Co. of NYSupreme Court of the United States · 1961
- Chesbro v. CommissionerUnited States Tax Court · 1953
8 more not listed; retrieve them via the Exa API.
3Cited by4 opinions
- National Ass'n of Life Underwriters v. CommissionerUnited States Tax Court · 1992
- Consolidated Industries, Inc., Joseph C. Valentine and Shirley R. Valentine, Ronald J. Clayton and Jane H. Clayton v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1985
- Consolidated Industries, Inc. v. CommissionerUnited States Tax Court · 1984
- Libutti v. Comm'rUnited States Tax Court · 1985