Legal Opinion

Founders Assoc. v. Commissioner

United States Board of Tax Appeals

Decided November 14, 1933No. Docket No. 62684PublishedCited by 1 opinion

The corporation income tax rates for the calendar year 1928 are not applicable to any part of the income of an association which was organized February 4, 1929, and which made its first return for the fiscal period ended November 30, 1929.

1Opinion of the Court

opinion.

Smith:

The petitioner contests a deficiency in income tax in the amount of $767.33 for its first fiscal period ended November 30,1929. The point in issue is the correct method of computing the tax liability for the return period.

The petitioner is a Massachusetts common law trust, created by agreement or declaration of trust on February 4, 1929, upon which date it began business. It adopted November 30 as the end of its fiscal year, closed its books as of November 30, 1929, and thereafter filed its return as an association covering its income from the date of organization to November…

2Cases cited1 opinion

  1. Bankers' Trust Co. v. BowersCourt of Appeals for the Second Circuit · 1923

3Cited by1 opinion

  1. Founders Assoc. v. CommissionerUnited States Board of Tax Appeals · 1933

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