Jordahl & Co. v. Commissioner
United States Board of Tax Appeals
1. (a), (b), and (c). - The petitioner in 1927 sold shares of stock of a subsidiary corporation at an amount less than the cost of such shares but greater than the cost reduced by the prior years' operating losses of the subsidiary which were availed of to reduce the taxable income reported in consolidated returns filed by the affiliated group. Held, that the transaction resulted in neither a deductible loss nor a taxable gain to the petitioner.
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1. (a), (b), and (c). - The petitioner in 1927 sold shares of stock of a subsidiary corporation at an amount less than the cost of such shares but greater than the cost reduced by the prior years' operating losses of the subsidiary which were availed of to reduce the taxable income reported in consolidated returns filed by the affiliated group. Held, that the transaction resulted in neither a deductible loss nor a taxable gain to the petitioner. The prior years' operating losses of the subsidiary are to be applied as a limitation upon the deduction allowable to the parent company, but do not…
1Opinion of the Court
JORDAHL & COMPANY, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Jordahl & Co. v. Commissioner
Docket No. 59581.
United States Board of Tax Appeals
35 B.T.A. 1136; 1937 BTA LEXIS 791;
May 27, 1937, Promulgated
1. (a), (b), and (c). - The petitioner in 1927 sold shares of stock of a subsidiary corporation at an amount less than the cost of such shares but greater than the cost reduced by the prior years' operating losses of the subsidiary which were availed of to reduce the taxable income reported in consolidated returns filed by the affiliated group. Held, that the transaction…
2Cases cited1 opinion
- Jordahl & Co. v. CommissionerUnited States Board of Tax Appeals · 1937