Wolverine Petroleum Corp. v. Commissioner
United States Board of Tax Appeals
The petitioner and other corporations affiliated with it changed their accounting period from a fiscal to a calendar year and filed a consolidated return for the last eight months of 1923. The respondent determined that the affiliation ceased August 31, 1923, on account of which he computed the tax liability of the affiliated group for the first four months on the basis of a consolidated return and the tax liability of the petitioner for the last four months on the basis of…
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The petitioner and other corporations affiliated with it changed their accounting period from a fiscal to a calendar year and filed a consolidated return for the last eight months of 1923. The respondent determined that the affiliation ceased August 31, 1923, on account of which he computed the tax liability of the affiliated group for the first four months on the basis of a consolidated return and the tax liability of the petitioner for the last four months on the basis of a separate return. Thereafter a closing agreement was entered into with the affiliated group for the period May 1, 1923,…
1Opinion of the Court
*1239OPINION.
Seawell:
The petitioner asks us to set aside the respondent’s conclusion that the last eight months of 1923 constitute two taxable periods of four months each, requiring a consolidated return of the affiliated group for the first period and a separate return of the petitioner for the second period, and to hold that the income tax liability of the affiliated group should be computed on the basis of a consolidated return for the entire eight months. The respondent argues that the closing agreement bars a decision in favor of the petitioner.
There is agreement that the respondent split the…
2Cases cited4 opinions
- General Box Corp. v. CommissionerUnited States Board of Tax Appeals · 1931
- Riley Stoker Corp. v. CommissionerUnited States Board of Tax Appeals · 1932
- Industrial Cotton Mills Co. v. CommissionerUnited States Board of Tax Appeals · 1931
- Newblock Oil Co. of Texas v. CommissionerUnited States Board of Tax Appeals · 1932
3Cited by10 opinions
- Zaentz v. CommissionerUnited States Tax Court · 1988
- Hopkins v. Comm'rUnited States Tax Court · 2003
- Smith Paper Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- H Graphics/Access, Ltd. Partnership v. CommissionerUnited States Tax Court · 1992
- Davis v. CommissionerUnited States Tax Court · 1989
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