Corno Mills Co. v. Commissioner
United States Board of Tax Appeals
NET LOSS - STATUTORY "TAXABLE YEAR." - Incident to the voluntary change in 1924 of the accounting period of the petitioner from a fiscal year ending November 30 to a calendar year, made with the full approval of the Commissioner, a separate return was filed and accepted for the month of December, 1924. Pennsylvania Electric Steel Casting Co.,20 B.T.A. 602, followed in holding that the one month of December, 1924, for which an income-tax return was made, was the third taxable…
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NET LOSS - STATUTORY "TAXABLE YEAR." - Incident to the voluntary change in 1924 of the accounting period of the petitioner from a fiscal year ending November 30 to a calendar year, made with the full approval of the Commissioner, a separate return was filed and accepted for the month of December, 1924. Pennsylvania Electric Steel Casting Co.,20 B.T.A. 602, followed in holding that the one month of December, 1924, for which an income-tax return was made, was the third taxable year in the contemplation of section 206(b) of the Revenue Act of 1926 and that the unexhausted balance of the net loss…
1Opinion of the Court
*713OPINION.
Teussell :
In the case of Pennsylvania Electric Steel Casting Co., 20 B. T. A. 602, the Board had before it a claim for net loss deduction in all respects similar to the situation in the instant case. It was there held that a net loss sustained during a fiscal year ending August 31, 1923—
* * * having been allowed as a deduction in computing the petitioner’s net income for the fiscal year ending August 31, 1924, and in computing the petitioner’s net income for the four-month period ending December 31, 1924, which period constitutes a “ taxable year” within the meaning of the statute, we…
2Cited by2 opinions
- Campbell-Fairbanks Expositions, Inc. v. United StatesDistrict Court, D. Massachusetts · 1943
- Corno Mills Co. v. CommissionerUnited States Board of Tax Appeals · 1930