Corn Belt Hatcheries, Inc. v. Commissioner
United States Tax Court
Shortly after the enactment of the Revenue Act of 1962, petitioner filed its first consolidated return for its 1962 fiscal year. For its 1963 fiscal year, petitioner elected to file a separate return. Held, in view of the ambiguity in Rev. Rul. 62-204, petitioner's election to file a separate return was timely.
1Opinion of the Court
OPINION
Tannenwald, Judge:
Respondent determined a deficiency in petitioner’s income tax for the taxable year ending August 31,1963, in the amount of $26,035. The sole issue for our determination is whether respondent properly computed petitioner’s liability on the basis of a consolidated return with its subsidiary, Rocky Mound Farms, Inc., or whether petitioner was entitled to file a separate return.
The case was submitted under Rule 30 of the Rules of Practice of this Court. All of the facts are stipulated and are found accordingly.
Petitioner, an Arkansas corporation, maintained its principal…
2Cases cited3 opinions
- Haggar Co. v. Helvering, Com'r of Internal RevenueSupreme Court of the United States · 1940
- Lang v. CommissionerSupreme Court of the United States · 1933
- Commercial Shearing & Stamping Co. v. CommissionerUnited States Tax Court · 1961
3Cited by23 opinions
- Dunn v. CommissionerUnited States Tax Court · 1978
- Gottesman & Co. v. CommissionerUnited States Tax Court · 1981
- Addison International, Inc. v. CommissionerUnited States Tax Court · 1988
- Dover Corp. v. Comm'rUnited States Tax Court · 2004
- CSX Corp. v. CommissionerUnited States Tax Court · 1987
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