Landy Towel & Linen Service, Inc. v. Commissioner
United States Tax Court
Petitioners became affiliated February 1, 1954, with petitioner in Docket No. 86288 as the parent corporation. The parent filed a consolidated return for the group for its calendar year 1954, including therein the income of the subsidiaries from July 1 to December 31, 1954, and also filed consolidated returns for the years 1955 and 1956, including all the income of the subsidiaries therein.
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Petitioners became affiliated February 1, 1954, with petitioner in Docket No. 86288 as the parent corporation. The parent filed a consolidated return for the group for its calendar year 1954, including therein the income of the subsidiaries from July 1 to December 31, 1954, and also filed consolidated returns for the years 1955 and 1956, including all the income of the subsidiaries therein. Each subsidiary filed a separate return for its fiscal year ending June 30, 1954, but did not file separate returns thereafter. The subsidiaries did not file the authorization and consent forms, Form 1122,…
1Opinion of the Court
OPINION.
Drennen, Judge:
Bespondent, on January 26, 1960, in separate notices of deficiency, determined deficiencies in income tax against petitioners as follows:
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Petitioners in Docket Nos. 86289, 86290, 86291, and 86292 are all wholly owned subsidiaries of petitioner in Docket No. 86288.
The only issue remaining for decision in this consolidated proceeding is whether respondent’s determination of the tax liability of all the petitioners on the basis of a consolidated return for the period February 1 to December 31,1954, and for the years 1955 and 1956 was correct.2
The case was…
2Cases cited18 opinions
- Charles Ilfeld Co. v. HernandezSupreme Court of the United States · 1934
- Maletis v. United StatesCourt of Appeals for the Ninth Circuit · 1952
- Burke & Herbert Bank & Trust Co. v. CommissionerUnited States Tax Court · 1948
- Alameda Inv. Co. v. McLaughlinCourt of Appeals for the Ninth Circuit · 1929
- American Trans-Ocean Navigation Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1956
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3Cited by14 opinions
- Salem Packing Co. v. CommissionerUnited States Tax Court · 1971
- Jones v. CommissionerUnited States Tax Court · 1963
- Davis Bros. Restaurant, Inc. v. CommissionerUnited States Tax Court · 1973
- C & R Investments, Inc. (Formerly Sherold Crystals, Inc.), a Corporation v. United StatesCourt of Appeals for the Tenth Circuit · 1971
- C & R Investments, Inc. v. United StatesDistrict Court, D. Kansas · 1969
9 more not listed; retrieve them via the Exa API.