Legal Opinion

Fajardo Sugar Co. v. Commissioner

United States Board of Tax Appeals

Decided September 25, 1930No. Docket No. 16544Published

1. A net loss for a period ended July 31, 1919, there being no income for the year ended July 31, 1920, may not be deducted in computing taxable income for the year ended July 31, 1921. 2. Under the Revenue Act of 1921, expenditures made by a foreign corporation in conducting its business are deductible in computing its taxable income from sources within the United States only when allocable to the production of income from sources within the United States or where a ratable…

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1. A net loss for a period ended July 31, 1919, there being no income for the year ended July 31, 1920, may not be deducted in computing taxable income for the year ended July 31, 1921. 2. Under the Revenue Act of 1921, expenditures made by a foreign corporation in conducting its business are deductible in computing its taxable income from sources within the United States only when allocable to the production of income from sources within the United States or where a ratable part of general expenditures is apportioned to income from sources within the United States. Where the Commissioner has…

1Opinion of the Court

FAJARDO SUGAR CO. OF PORTO RICO, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Fajardo Sugar Co. v. Commissioner

Docket No. 16544.

United States Board of Tax Appeals

20 B.T.A. 980; 1930 BTA LEXIS 1989;

September 25, 1930, Promulgated

1. A net loss for a period ended July 31, 1919, there being no income for the year ended July 31, 1920, may not be deducted in computing taxable income for the year ended July 31, 1921.

2. Under the Revenue Act of 1921, expenditures made by a foreign corporation in conducting its business are deductible in computing its taxable income from sources within…

2Cases cited1 opinion

  1. Fajardo Sugar Co. v. CommissionerUnited States Board of Tax Appeals · 1930

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