Trinco Industries, Inc. v. Commissioner
United States Tax Court
1. Petitioner, a corporation which in July and November of 1949 acquired the stock of two other corporations, may not carry back and apply against its income for the year ending June 30, 1948, the loss sustained by one of its subsidiaries during the year ending June 30, 1950, for which year petitioner and its subsidiaries joined in a consolidated return. 2. Petitioner is not entitled to a bad debt deduction for the year ending June 30, 1950, of a portion of amounts lent to a…
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1. Petitioner, a corporation which in July and November of 1949 acquired the stock of two other corporations, may not carry back and apply against its income for the year ending June 30, 1948, the loss sustained by one of its subsidiaries during the year ending June 30, 1950, for which year petitioner and its subsidiaries joined in a consolidated return. 2. Petitioner is not entitled to a bad debt deduction for the year ending June 30, 1950, of a portion of amounts lent to a subsidiary during that year.
1Opinion of the Court
OPINION.
Raum, Judge:
1. The petitioner’s principal contention is that it is entitled to carry back to its taxable year ending June 30, 1948, and apply against its income for that year not only the loss which it sustained for the taxable year ending June 30, 1950, but also the loss sustained for the taxable year ending June 30,1950, by its subsidiary, the Minute Mop Factory (Canada), Limited. We think that the deduction thus claimed on account of the loss sustained by the subsidiary is not allowable under the statute and applicable regulations. The problem is one that does not come to us…
2Cases cited17 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Interstate Transit Lines v. CommissionerSupreme Court of the United States · 1943
- National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
- Woolford Realty Co. v. RoseSupreme Court of the United States · 1932
- Standard Paving Co. v. Commissioner of Internal Revenue. Standard Paving Co. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1951
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3Cited by56 opinions
- Riss v. CommissionerUnited States Tax Court · 1971
- Crown v. CommissionerUnited States Tax Court · 1981
- Seaboard Commercial Corp. v. CommissionerUnited States Tax Court · 1957
- Roth Steel Tube Company v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1980
- Roussel v. CommissionerUnited States Tax Court · 1961
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