Handy & Harman v. Burnet

Mr. Justice * Butler

delivered the opinion of' the. Court.

Petitioner claims that it and Hamilton & DeLoss, Inc., were affiliated corporations as defined by § 240 of the Revenue Act of 1918 and that it is entitled to have its net income and invested capital for 1918 and the first month of 1919 determined on the basis of consolidated returns. The Commissioner of Internal Revenue held them not affiliated, rejected petitioner’s claim for abatement for 1918 and asserted a deficiency for 1919. The Board of Tax Appeals approved the Commissioner’s determination (17 B. T. A. 980) and upon petition for…