Pokorny Realty Co. v. United States

WILLIAMS, Judge.

The plaintiff claims that during the taxable year ending May 31, 1923, it was, within the meaning of the applicable statutes, affiliated with two other corporations, to wit, M. Pokorny & Sons, Limited, and Pokorny Estate, Inc.; that during the taxable years ending, respectively, May 33, 1924, and May 31, 3926, it was affiliated with M. Pokorny & Sons, Limited; and that it is entitled to have its tax liability for those years computed on the basis of such affiliations instead of on *240its own separate return, as held by the Commissioner of.Internal Revenue.

If plaintiff is entitled…