Carter, Rice & Co. v. Commissioner
United States Board of Tax Appeals
1. A net loss sustained by a corporation prior to affiliation may be applied against, and to the amount of, its income for the succeeding year, after it becomes a member of the affiliated group.
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1. A net loss sustained by a corporation prior to affiliation may be applied against, and to the amount of, its income for the succeeding year, after it becomes a member of the affiliated group. The excess of the loss, however, may not be applied against the consolidated income of the group. 2. A corporation keeping its accounts upon an accrual basis may not credit against its domestic tax liability for 1928 amounts paid by it in that year to a foreign government in discharge of additional tax liabilities for prior years, since such amounts are proper accruals for those years to which the tax…
1Opinion of the Court
OPINION.
Goodrich:
Respondent determined a deficiency in income tax for 1928 of $232.70. Petitioner contends that it is not liable for the deficiency, but moreover, has already overpaid its income tax liability for 1928, and that the amount in controversy is $2,620.65. Petitioner *688alleges that respondent’s determination is in error in the following particulars: (1) Failing to allow as a deduction from the consolidated net income for 1928 of an affiliated group of corporations the whole of the statutory net loss for 1927 of the Nashua Youngblood Co., which became affiliated with the group in…
2Cases cited9 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Woolford Realty Co. v. RoseSupreme Court of the United States · 1932
- Marr v. United StatesSupreme Court of the United States · 1925
- Delaware & Hudson Co. v. CommissionerUnited States Board of Tax Appeals · 1932
- Reubel v. CommissionerUnited States Board of Tax Appeals · 1925
4 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Ferrer v. CommissionerUnited States Tax Court · 1961
- American Air Filter Co. v. CommissionerUnited States Tax Court · 1983
- Amp Incorporated and Consolidated Subsidiaries v. United StatesCourt of Appeals for the Federal Circuit · 1999
- American Air Filter Co. v. CommissionerUnited States Tax Court · 1983
- Carter, Rice & Co. v. CommissionerUnited States Board of Tax Appeals · 1933
1 more not listed; retrieve them via the Exa API.