Tolerton & Warfield Co. v. Commissioner
United States Board of Tax Appeals
1. Periods of less than a year for which returns are required held, under the Revenue Act of 1924, to be taxable years for purpose of computation of net loss. 2. Net losses sustained prior to affiliation may be used in computing consolidated net income. Ben Ginsburg Co.,19 B.T.A. 81, followed.
1Opinion of the Court
*894OPINION.
Arundell:
Although the Tackaberry Company owned 100 per cent of the stock of the Realty Company, each filed separate returns for the fiscal year ended January 31, 1924. For the period from February 1 to April 26, 1924, these two companies filed consolidated returns and while this action is not explained it is not contested. On April 26,1924, the petitioner acquired 100 per cent of the stock of the Tackaberry Company, thus mailing possible the filing of consolidated returns by all three companies. The petitioner in a consolidated return reported its income for the calendar year 1924,…
2Cited by1 opinion
- Tolerton & Warfield Co. v. CommissionerUnited States Board of Tax Appeals · 1931