Automobile Loans, Inc. v. Commissioner
United States Board of Tax Appeals
The petitioner, a personal holding company, filed the prescribed return for surtax on such corporation, after March 15, but within an extension of time allowed. The shareholders of the petitioner corporation filed their returns March 15 without reporting in gross income their pro rata shares of petitioner's adjusted net income.
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The petitioner, a personal holding company, filed the prescribed return for surtax on such corporation, after March 15, but within an extension of time allowed. The shareholders of the petitioner corporation filed their returns March 15 without reporting in gross income their pro rata shares of petitioner's adjusted net income. Later, at the time petitioner filed its surtax return, the shareholders filed "amended returns" reporting gross income so as to include their pro rata shares of petitioner's adjusted net income. Held that "the time a filing their retrns" was when the first returns were…
1Opinion of the Court
OPINION.
Harron:
The petitioner is a corporation incorporated under the laws of the State of Washington, with its office in Seattle. It filed an income tax return for the year 1934 with the collector for the district of Washington. The Commissioner issued a notice of deficiency for the year 1934 in the amounts of $1,103.17, surtax liability of a personal holding company pursuant to section 351 (a) of the Revenue Act of 1934, and $275.79, 25 percent addition to tax pursuant to section 291 of the Revenue Act of 1934. The respondent has conceded by stipulation that the 25 percent addition to tax…
2Cited by3 opinions
- Automobile Loans, Inc. v. CommissionerUnited States Board of Tax Appeals · 1937
- Clay v. CommissionerUnited States Board of Tax Appeals · 1939
- William A. Webster Co. v. CommissionerUnited States Board of Tax Appeals · 1938