General Box Corp. v. Commissioner
United States Board of Tax Appeals
Four separate companies had net losses in 1921; three of them had net losses in the first two months of 1922 and one had a net income in that period.
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Four separate companies had net losses in 1921; three of them had net losses in the first two months of 1922 and one had a net income in that period. The four became affiliated on March 1, 1922, and remained affiliated throughout the remainder of that year and the calendar year 1923. Held that the first two months of 1922 do not constitute a taxable year and that the 1921 net losses should be applied to 1922 and 1923 income, in accordance with the decisions in Alabama By-Products Corporation,18 B.T.A. 919, and Swift & Co. v. United States,69 Ct.Cls. 171; 38 Fed.(2d) 365.
1Opinion of the Court
GENERAL BOX CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
General Box Corp. v. Commissioner
Docket No. 32198.
United States Board of Tax Appeals
22 B.T.A. 725; 1931 BTA LEXIS 2076;
March 13, 1931, Promulgated
Four separate companies had net losses in 1921; three of them had net losses in the first two months of 1922 and one had a net income in that period. The four became affiliated on March 1, 1922, and remained affiliated throughout the remainder of that year and the calendar year 1923. Held that the first two months of 1922 do not constitute a taxable year and that…
2Cases cited2 opinions
- Alabama By-Products Corp. v. CommissionerUnited States Board of Tax Appeals · 1930
- General Box Corp. v. CommissionerUnited States Board of Tax Appeals · 1931