Summerfield Co. v. Commissioner
United States Board of Tax Appeals
The petitioner and the Taylor Furniture Company, separate corporations, became affiliated March 21, 1925, and affiliation continued through the year. The Taylor Furniture Company had a net loss in the calendar year 1924, in the period January 1 to March 20, 1925, and also for the period March 21 to December 31, 1925, for each of which periods the petitioner had net income.
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The petitioner and the Taylor Furniture Company, separate corporations, became affiliated March 21, 1925, and affiliation continued through the year. The Taylor Furniture Company had a net loss in the calendar year 1924, in the period January 1 to March 20, 1925, and also for the period March 21 to December 31, 1925, for each of which periods the petitioner had net income. Held, each of said periods is, within the meaning of the Revenue Act of 1926, a taxable year and the net losses of the Taylor Furniture Company for the calendar year 1924 and the period January 1 to March 20, 1925, may be…
1Opinion of the Court
SUMMERFIELD COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Summerfield Co. v. Commissioner
Docket Nos. 33651, 36869, 47462.
United States Board of Tax Appeals
24 B.T.A. 829; 1931 BTA LEXIS 1586;
November 18, 1931, Promulgated
The petitioner and the Taylor Furniture Company, separate corporations, became affiliated March 21, 1925, and affiliation continued through the year. The Taylor Furniture Company had a net loss in the calendar year 1924, in the period January 1 to March 20, 1925, and also for the period March 21 to December 31, 1925, for each of which periods the…
2Cases cited9 opinions
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- General Box Corp. v. CommissionerUnited States Board of Tax Appeals · 1931
- American La Dentelle, Inc. v. CommissionerUnited States Board of Tax Appeals · 1925
- Pennsylvania Electric Steel Casting Co. v. CommissionerUnited States Board of Tax Appeals · 1930
- Ben Ginsburg Co. v. CommissionerUnited States Board of Tax Appeals · 1930
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