Imperial Assurance Co. v. Commissioner
United States Board of Tax Appeals
AFFILIATION - RETURNS - ELECTION. - Where four corporations were affiliated during the taxable year 1922 and filed separate returns, and the same four corporations were affiliated during the year 1923 with two others, they can not file a consolidated return for 1923 without the permission of the Commissioner.
1Opinion of the Court
IMPERIAL ASSURANCE CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
UNITED FIREMEN'S INSURANCE CO. OF PHILADELPHIA, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Imperial Assurance Co. v. Commissioner
Docket Nos. 29735, 29736.
United States Board of Tax Appeals
19 B.T.A. 1068; 1930 BTA LEXIS 2267;
May 23, 1930, Promulgated
AFFILIATION - RETURNS - ELECTION. - Where four corporations were affiliated during the taxable year 1922 and filed separate returns, and the same four corporations were affiliated during the year 1923 with two others, they can not file a…
2Cases cited4 opinions
- Imperial Assurance Co. v. CommissionerUnited States Board of Tax Appeals · 1930
- Sweets Co. of America, Inc. v. CommissionerUnited States Board of Tax Appeals · 1928
- B. B. Bathing Park, Inc. v. CommissionerUnited States Board of Tax Appeals · 1929
- St. Louis Nat'l Baseball Club v. CommissionerUnited States Board of Tax Appeals · 1929