Legal Opinion

Texas Land & Mortg. Co. v. Commissioner

United States Board of Tax Appeals

Decided June 7, 1934No. Docket No. 67521Published

In determining the ratable part of the expenses, losses, and other deductions of a foreign corporation which can not definitely be allocated to some item or class of gross income for the purpose of computing the net income from sources within the United States, held that the gross income from all sources is not to be reduced by the amount of total losses from the sale of securities and that the gross income from sources within the United States is not to be reduced by the…

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In determining the ratable part of the expenses, losses, and other deductions of a foreign corporation which can not definitely be allocated to some item or class of gross income for the purpose of computing the net income from sources within the United States, held that the gross income from all sources is not to be reduced by the amount of total losses from the sale of securities and that the gross income from sources within the United States is not to be reduced by the amount of losses from the sale of securities in the United States.

1Opinion of the Court

THE TEXAS LAND & MORTGAGE COMPANY, LTD., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Texas Land & Mortg. Co. v. Commissioner

Docket No. 67521.

United States Board of Tax Appeals

30 B.T.A. 861; 1934 BTA LEXIS 1252;

June 7, 1934, Promulgated

In determining the ratable part of the expenses, losses, and other deductions of a foreign corporation which can not definitely be allocated to some item or class of gross income for the purpose of computing the net income from sources within the United States, held that the gross income from all sources is not to be reduced by the amount of…

2Cases cited1 opinion

  1. Texas Land & Mortg. Co. v. CommissionerUnited States Board of Tax Appeals · 1934

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