Legal Opinion

Landy Towel & Linen Service, Inc. v. Commissioner

United States Tax Court

Decided May 18, 1962No. Docket Nos. 86288-86292Published

Petitioners became affiliated February 1, 1954, with petitioner in Docket No. 86288 as the parent corporation. The parent filed a consolidated return for the group for its calendar year 1954, including therein the income of the subsidiaries from July 1 to December 31, 1954, and also filed consolidated returns for the years 1955 and 1956, including all the income of the subsidiaries therein.

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Petitioners became affiliated February 1, 1954, with petitioner in Docket No. 86288 as the parent corporation. The parent filed a consolidated return for the group for its calendar year 1954, including therein the income of the subsidiaries from July 1 to December 31, 1954, and also filed consolidated returns for the years 1955 and 1956, including all the income of the subsidiaries therein. Each subsidiary filed a separate return for its fiscal year ending June 30, 1954, but did not file separate returns thereafter. The subsidiaries did not file the authorization and consent forms, Form 1122,…

1Opinion of the Court

Landy Towel & Linen Service, Inc. of Reading, Pa., et al., 1 Petitioners, v. Commissioner of Internal Revenue, Respondent

Landy Towel & Linen Service, Inc. v. Commissioner

Docket Nos. 86288-86292

United States Tax Court

38 T.C. 296; 1962 U.S. Tax Ct. LEXIS 132;

May 18, 1962, Filed

Decisions will be entered under Rule 50.

Petitioners became affiliated February 1, 1954, with petitioner in Docket No. 86288 as the parent corporation. The parent filed a consolidated return for the group for its calendar year 1954, including therein the income of the subsidiaries from July 1 to December 31, 1954, and also…

2Cases cited19 opinions

  1. Charles Ilfeld Co. v. HernandezSupreme Court of the United States · 1934
  2. Maletis v. United StatesCourt of Appeals for the Ninth Circuit · 1952
  3. Burke & Herbert Bank & Trust Co. v. CommissionerUnited States Tax Court · 1948
  4. Alameda Inv. Co. v. McLaughlinCourt of Appeals for the Ninth Circuit · 1929
  5. American Trans-Ocean Navigation Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1956

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