Western Hide & Fur Co. v. Commissioner
United States Board of Tax Appeals
A taxpayer invoking the provisions of section 240(d) of the Revenue Act of 1924, and section 240(f) of the Revenue Act of 1926, for the consolidation of its accounts with those of another corporation must show the necessity for the consolidation and a method of "accurate distribution or apportionment" of the income and expenses of the two companies engaged in related trades or businesses and owned or controlled by the same interests.
1Opinion of the Court
*357OPINION.
Smith:
Section 240 (d) of the Revenue Act of 1924 and section 240 (f) of the Revenue Act of 1926 are identical and are as follows:
In any ease of two or more related trades or businesses (whether unincorporated or incorporated and whether organized in the United States or not) owned or controlled directly or indirectly by the same interests, the Commissioner may and at the request of the taxpayer shall, if necessary in order *358to make an accurate distribution or apportionment of gains, profits, income, deductions, or capital between or among sueli related trades or businesses, consolidate…
2Cited by8 opinions
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- Remco S. S. Co. v. CommissionerCourt of Appeals for the Ninth Circuit · 1936
- Remco Steamship Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- ACKERMAN v. COMMISSIONERUnited States Board of Tax Appeals · 1932
- Autocar Co. v. CommissionerUnited States Board of Tax Appeals · 1934
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