Alworth v. Commissioner
United States Board of Tax Appeals
Federal income and excess profits taxes paid in the following year held not deductible by corporations on the cash basis in computing their "adjusted net income" under section 351, Revenue Act of 1934.
1Opinion of the Court
OPINION.
Opper :
Petitioner, the sole stockholder of two corporations which are concededly personal holding companies within the meaning of section 351 of the Revenue Act of 1934,1 in order to obtain for these corporations the benefit of the remission of tax provided by subdivision (d) of that section, returned as his income what purported to be the entire “adjusted net income” of the respective corporations for the year 1934. The dispute here is whether in fact he did so, the item giving rise to that dispute being the amount of Federal income and excess profits tax due from the corporations…
2Cited by8 opinions
- Arc Realty Co. v. CommissionerUnited States Tax Court · 1960
- Mariani Frozen Foods, Inc. v. CommissionerUnited States Tax Court · 1983
- Mills, Incorporated v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1957
- Rodney, Inc. v. HoeyDistrict Court, S.D. New York · 1944
- Alworth v. CommissionerUnited States Board of Tax Appeals · 1938
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