Legal Opinion

Commercial Shearing & Stamping Co. v. Commissioner

United States Tax Court

Decided May 26, 1961No. Docket Nos. 76778, 84338, 85427Published

Filing by petitioner corporation and its subsidiaries of a consolidated return for its first fiscal year after enactment of 1954 Code but under applicable 1939 Code regulations, held, not to preclude new election to file separate returns for following year after promulgation of new and less favorable regulations under 1954 Code.

1Opinion of the Court

Commercial Shearing & Stamping Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

Commercial Shearing & Stamping Co. v. Commissioner

Docket Nos. 76778, 84338, 85427

United States Tax Court

36 T.C. 433; 1961 U.S. Tax Ct. LEXIS 137;

May 26, 1961, Filed

Decisions will be entered under Rule 50.

Filing by petitioner corporation and its subsidiaries of a consolidated return for its first fiscal year after enactment of 1954 Code but under applicable 1939 Code regulations, held, not to preclude new election to file separate returns for following year after promulgation of new and less…

2Cases cited4 opinions

  1. Helvering v. R. J. Reynolds Tobacco Co.Supreme Court of the United States · 1939
  2. Lucas v. Sterling Oil & Gas Co.Court of Appeals for the Sixth Circuit · 1933
  3. Commercial Shearing & Stamping Co. v. CommissionerUnited States Tax Court · 1961
  4. Cereal Products Refining Corp. v. CommissionerUnited States Board of Tax Appeals · 1939

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