New England Power Co. v. Commissioner
United States Board of Tax Appeals
1. STATUTE OF LIMITATIONS. Consolidated returns filed for 1918 and 1919 held to meet the statutory requirements as to filing returns. Assessment for 1918 was timely made on March 15, 1924, but the deficiency notice was not mailed until after the statutory period, as extended by a waiver, had expired and it is held that collection is barred. Assessment for 1919 was made more than five years after the return was filed and it is held that collection is barred. 2. AFFILIATION.
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1. STATUTE OF LIMITATIONS. Consolidated returns filed for 1918 and 1919 held to meet the statutory requirements as to filing returns. Assessment for 1918 was timely made on March 15, 1924, but the deficiency notice was not mailed until after the statutory period, as extended by a waiver, had expired and it is held that collection is barred. Assessment for 1919 was made more than five years after the return was filed and it is held that collection is barred. 2. AFFILIATION. Petitioners held not affiliated with the New England Company. 3. DEDUCTION. Parent company loaned money to a wholly owned…
1Opinion of the Court
*204OPINION.
Arundell :
At the outset we must consider the suggestion of lack of jurisdiction in the Connecticut River Power Company case, Docket *205No. 18591, in so far as the year 1918 is concerned. The original return, a consolidated return, showed no tax due from this company separately. On March 15, 1924, the respondent, after refusing to' allow affiliation, assessed against this petitioner $175,183.43. Abatement claim was filed, which was allowed for $144,299.28 and rejected to the extent of $30,884.15. This latter amount was satisfied to the extent of $20,834.51, partly by credit and partly by…
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- Rensselaer & S. R. v. IrwinCourt of Appeals for the Second Circuit · 1918
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- Fenwal, Inc. v. CommissionerUnited States Tax Court · 1949
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