General Finance Co. v. Commissioner

DAVIS, Circuit Judge.

This is an appeal from an order of redetermination by the Board of Tax Appeals which denied the petitioner the' right to deduct, in its income tax returns, net losses sustained in the two years prior to the time when, as a Delaware corporation, it became “domesticated” under the laws of Pennsylvania.

In 1921 the petitioner was incorporated in the state of 'Delaware. Its sole office and place of business was in Philadelphia. From 1921 to 1929 the petitioner complied with the statutes; taxing and otherwise, of Pennsylvania dealing with foreign corporations, and filed…