General Mfg. Corp. v. Commissioner
United States Tax Court
Held, that petitioner was not entitled to file a consolidated return with its parent corporation for the taxable year ended October 31, 1957, because it did not make a timely consent to the filing of a consolidated return and the parent corporation, which for prior years filed its return on a calendar year basis, did not obtain approval of Commissioner to change to a fiscal year basis for reporting income.
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Held, that petitioner was not entitled to file a consolidated return with its parent corporation for the taxable year ended October 31, 1957, because it did not make a timely consent to the filing of a consolidated return and the parent corporation, which for prior years filed its return on a calendar year basis, did not obtain approval of Commissioner to change to a fiscal year basis for reporting income. Held, further, that the consolidated return, which was filed in good faith and disclosed items of income and deductions of petitioner necessary for computation of tax, constituted the…
1Opinion of the Court
General Manufacturing Corp., Petitioner, v. Commissioner of Internal Revenue, Respondent
General Mfg. Corp. v. Commissioner
Docket No. 5386-63
United States Tax Court
44 T.C. 513; 1965 U.S. Tax Ct. LEXIS 61;
July 2, 1965, Filed
Decision will be entered for the petitioner.
Held, that petitioner was not entitled to file a consolidated return with its parent corporation for the taxable year ended October 31, 1957, because it did not make a timely consent to the filing of a consolidated return and the parent corporation, which for prior years filed its return on a calendar year basis, did not obtain…
2Cases cited14 opinions
- Commissioner v. Lane-Wells Co.Supreme Court of the United States · 1944
- Zellerbach Paper Co. v. HelveringSupreme Court of the United States · 1934
- Germantown Trust Co. v. CommissionerSupreme Court of the United States · 1940
- Burford Oil Co. v. CommissionerUnited States Tax Court · 1945
- Burford Oil Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1946
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