Buckie Printers' Ink Co. v. Commissioner
United States Board of Tax Appeals
NET LOSS - DEDUCTION IN CASE OF AFFILIATED COMPANIES. - The remainder of a net loss in 1922, after deducting the net income of the same taxpayer for 1923, is allowable as a deduction in computing net income for the third year, 1924, and the resulting net income or loss should be considered in full in arriving at the consolidated net income of a consolidation of which the 1922 loser is a member, even though such member had a loss for 1924 previous to deducting the net loss…
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NET LOSS - DEDUCTION IN CASE OF AFFILIATED COMPANIES. - The remainder of a net loss in 1922, after deducting the net income of the same taxpayer for 1923, is allowable as a deduction in computing net income for the third year, 1924, and the resulting net income or loss should be considered in full in arriving at the consolidated net income of a consolidation of which the 1922 loser is a member, even though such member had a loss for 1924 previous to deducting the net loss for 1922. Moore Cotton Mills Co.,17 B.T.A. 662, and Alabama By-Products Corporation et al.,18 B.T.A. 919, followed.
1Opinion of the Court
*945OPINION.
Trussell:
The sole issue in this case is a question of the carrying forward to 1924 (the taxable year) of a net loss suffered in 1922.
We have previously had occasion to decide all of the points involved in this case. Section 206 (e) of the Revenue Act of 1924 provides that the amount of the excess of a net loss for 1922 over the net income for 1923 shall be “ allowed as a deduction in computing the net income for the taxable year 1924.” In Moore Cotton Mills Co., 17 B. T. A. 662, we decided that a provision of the Revenue Act of 1921 similarly worded should be literally interpreted. In…
2Cited by1 opinion
- Buckie Printers' Ink Co. v. CommissionerUnited States Board of Tax Appeals · 1930