American Fork & Hoe Co. v. Commissioner
United States Board of Tax Appeals
1. The petitioner, an Ohio corporation, owned, through two New York corporation, except qualifying shares. Held, that petitioner is not entitled to include the New York corporation in its consolidated return, following Commissioner v. Manus-Muller & Co., 79 Fed.(2d) 19; certiorari denied, 296 U.S. 657. 2. A taxpayer on the accrual basis can not be charged with income if there exists good reason for believing that the income can not be collected.
1Opinion of the Court
*1146OPINION.
Van Fossan:
In this opinion we will discuss the contested issues in the order hereinabove set forth.
*1147Issue I.
The petitioner contends that under section 141 (a), (d), and (e¡) of the Revenue Act of 1928,1 it is entitled to include the Cronk & Carrier Manufacturing Co. in its consolidated income tax return for the fiscal year ended June 80, 1929.
The petitioner bases its contention upon the statutory definition of an “affiliated group” which is “one or more chains of corporations connected through stock ownership with a common parent corporation.” The chain here begins with the petitioner…
2Cited by6 opinions
- Continental Illinois Corp. v. CommissionerUnited States Tax Court · 1991
- Portuguese-American Tin Co. v. CommissionerUnited States Tax Court · 1943
- Wilson v. CommissionerUnited States Tax Court · 1943
- American Fork & Hoe Co. v. CommissionerUnited States Board of Tax Appeals · 1936
- McGlue v. CommissionerUnited States Board of Tax Appeals · 1940
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