Consolidated Cos. v. Commissioner
United States Board of Tax Appeals
1. Amounts claimed as deductions from income for 1918, held not to be deductible in said year either as bad debts or losses, since the transactions giving rise thereto were not completed in said year. 2. Special assessment denied. 3. JURISDICTION. - All facts necessary to show jurisdiction in the Board must be pleaded and proved.
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1. Amounts claimed as deductions from income for 1918, held not to be deductible in said year either as bad debts or losses, since the transactions giving rise thereto were not completed in said year. 2. Special assessment denied. 3. JURISDICTION. - All facts necessary to show jurisdiction in the Board must be pleaded and proved. Where a petition is filed in the name of the taxpayer, a corporation which has been dissolved by cancellation of its charter, and where it is not alleged and does not affirmatively appear that the person filing the petition has lawful authority to act for and in…
1Opinion of the Court
*649OPINION.
Trammell:
In Docket No. 14080, the original petition was filed on April 23, 1926, in the name of Iberville Wholesale Grocery Co., Ltd., as petitioner. It is alleged in paragraph 1 of this pleading that “The taxpayer' was a Louisiana corporation with principal office at Plaquemine, Louisiana.” The petition was verified by an affidavit reading in part as follows:
Before me, the undersigned authority, personally came and appeared V. J. Kurzweg, who being duly sworn, deposes and says that he is Secretary and Treasurer of the Consolidated Companies, Inc., and was Secretary and Treasurer of…
2Cases cited1 opinion
- Oklahoma Natural Gas Co. v. OklahomaSupreme Court of the United States · 1927
3Cited by32 opinions
- Ewing v. Comm'rUnited States Tax Court · 2004
- Fehrs v. CommissionerUnited States Tax Court · 1975
- Brannon's of Shawnee, Inc. v. CommissionerUnited States Tax Court · 1978
- Commissioner v. NealCourt of Appeals for the Eleventh Circuit · 2009
- Fletcher Plastics, Inc. v. CommissionerUnited States Tax Court · 1975
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