Legal Opinion

American Creosoting Co. v. Commissioner

United States Board of Tax Appeals

Decided May 31, 1928No. Docket No. 17777Published

1. A corporation affiliated with another corporation under section 240 of the Revenue Act of 1918 does not lose its status as a "taxpayer" and an assessment against such corporation in the absence of an agreement that the taxes due from other affiliated corporations may be collected from it will not authorize the collection from it of taxes due from such other corporations, and a notice to it of a deficiency in taxes due from other affiliated corporations joining with it in…

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1. A corporation affiliated with another corporation under section 240 of the Revenue Act of 1918 does not lose its status as a "taxpayer" and an assessment against such corporation in the absence of an agreement that the taxes due from other affiliated corporations may be collected from it will not authorize the collection from it of taxes due from such other corporations, and a notice to it of a deficiency in taxes due from other affiliated corporations joining with it in filing a consolidated return will not authorize the filing with the Board of petitions for the redetermination of…

1Opinion of the Court

AMERICAN CREOSOTING CO., INC., ET AL., 1 PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

American Creosoting Co. v. Commissioner

Docket No. 17777.

United States Board of Tax Appeals

12 B.T.A. 247; 1928 BTA LEXIS 3573;

May 31, 1928, Promulgated

1. A corporation affiliated with another corporation under section 240 of the Revenue Act of 1918 does not lose its status as a "taxpayer" and an assessment against such corporation in the absence of an agreement that the taxes due from other affiliated corporations may be collected from it will not authorize the collection from it of taxes due…

2Cases cited1 opinion

  1. American Creosoting Co. v. CommissionerUnited States Board of Tax Appeals · 1928

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