Legal Opinion

BENEFICIAL LOAN SOCY. OF TRENTON v. COMMISSIONER

United States Board of Tax Appeals

Decided October 25, 1932No. Docket Nos. 47749, 48238, 49273, 60961, 61021Published

SPECIFIC CREDIT - CORPORATION - IN AND OUT OF AFFILIATION DURING TAXABLE YEAR. Where a corporation is a member of an affiliated group for part of a taxable year and its income for such part of the year is included in a consolidated return filed by a parent corporation, and files a separate return including income for the fractional part of the year during which it was unaffiliated, it is only entitled on its separate return to a pro rata part of the specific credit allowed…

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SPECIFIC CREDIT - CORPORATION - IN AND OUT OF AFFILIATION DURING TAXABLE YEAR. Where a corporation is a member of an affiliated group for part of a taxable year and its income for such part of the year is included in a consolidated return filed by a parent corporation, and files a separate return including income for the fractional part of the year during which it was unaffiliated, it is only entitled on its separate return to a pro rata part of the specific credit allowed corporations for a taxable year. (Beneficial Loan Society, 48 Fed.(2d) 686; Green River Distilling Co.,16 B.T.A. 395,…

1Opinion of the Court

BENEFICIAL LOAN SOCIETY OF TRENTON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

AMERICAN LOAN COMPANY OF AKRON, OHIO, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

AMERICAN LOAN COMPANY OF CAMDEN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

BENEFICIAL LOAN COMPANY OF PROVIDENCE, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

PERSONAL FINANCE COMPANY OF LEBANON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

BENEFICIAL LOAN SOCY. OF TRENTON v. COMMISSIONER

Docket Nos. 47749, 48238, 49273, 60961, 61021.

United States Board of…

2Cases cited2 opinions

  1. Green River Distilling Co. v. CommissionerUnited States Board of Tax Appeals · 1929
  2. BENEFICIAL LOAN SOCY. OF TRENTON v. COMMISSIONERUnited States Board of Tax Appeals · 1932

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