ACKERMAN v. COMMISSIONER
United States Board of Tax Appeals
1. The petitioner during the taxable year was a member of a partnership which held substantially all of the common voting stock of an operating corporation.
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1. The petitioner during the taxable year was a member of a partnership which held substantially all of the common voting stock of an operating corporation. Petitioner's contention that the accounts of the partnership and of the corporation should be consolidated, pursuant to the provisions of sections 240(d) and 240(f) of the Revenue Acts of 1924 and 1926, denied, in the absence of proof of the necessity for such consolidation of accounts and the facts essential for making an accurate and equitable apportionment of income and expense between the two related businesses. Roessler & Hasslacher…
1Opinion of the Court
*418OPINION.
Teammell :
The petitioner contends, first, that in determining the deficiencies for both taxable years here involved, the respondent erred in refusing to grant the petitioner’s request for a consolidation of the accounts of the partnership and of the corporation pursuant to the provisions of section 240 (d) and 240 (f) of the Revenue Acts of 1924 and 1926. These statutes are identical in form, and read as follows:
In any case of two or more related trades or businesses (whether unincorporated or incorporated and whether organized in the United States or not) owned or controlled directly…
2Cited by2 opinions
- Remco S. S. Co. v. CommissionerCourt of Appeals for the Ninth Circuit · 1936
- ACKERMAN v. COMMISSIONERUnited States Board of Tax Appeals · 1932