Legal Opinion

Fletcher American Nat'l Bank v. Commissioner

United States Board of Tax Appeals

Decided November 14, 1935No. Docket Nos. 43712, 43713, 47149, 47150, 47585, 51120-51124, 58966-58969Published

1. AFFILIATION - CONSOLIDATED RETURNS - REVENUE ACTS OF 1924, 1926 AND 1928. - Where no change in the parent of an affiliated group occurred in the taxable years, no right of election between the consolidated and separate basis of return accrued to petitioner because of the addition, in those years, of other companies to that group.

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1. AFFILIATION - CONSOLIDATED RETURNS - REVENUE ACTS OF 1924, 1926 AND 1928. - Where no change in the parent of an affiliated group occurred in the taxable years, no right of election between the consolidated and separate basis of return accrued to petitioner because of the addition, in those years, of other companies to that group. Export Leaf Tobacco Co. v. Commissioner, 78 Fed.(2d) 163, affirming 31 B.T.A. 28; certiorari denied, 296 U.S. 627; Huntington Beach, Inc.,30 B.T.A. 731, followed. 2. Id. - Under the provisions of the Revenue Acts of 1924, 1926 and 1928, the right of election, to…

1Opinion of the Court

FLETCHER AMERICAN NATIONAL BANK, PETITIONER, ET AL., 1v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Fletcher American Nat'l Bank v. Commissioner

Docket Nos. 43712, 43713, 47149, 47150, 47585, 51120-51124, 58966-58969.

United States Board of Tax Appeals

33 B.T.A. 453; 1935 BTA LEXIS 747;

November 14, 1935, Promulgated

1. AFFILIATION - CONSOLIDATED RETURNS - REVENUE ACTS OF 1924, 1926 AND 1928. - Where no change in the parent of an affiliated group occurred in the taxable years, no right of election between the consolidated and separate basis of return accrued to petitioner because of the…

2Cases cited3 opinions

  1. Smith Paper Co. v. CommissionerUnited States Board of Tax Appeals · 1934
  2. Huntington Beach, Inc. v. CommissionerUnited States Board of Tax Appeals · 1934
  3. Fletcher American Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1935

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