Consolidated Industries, Inc. v. Commissioner
United States Tax Court
Connecticut taxes corporations pursuant to a "piggy-back" system whereby Federal taxable income serves as the State taxable income base. The Commissioner and Consolidated (a Connecticut corporation and an accrual method taxpayer) reached an agreement in 1983 that part of Consolidated's 1976 Federal deduction for officers' salaries should be disallowed.
Read the full summary
Connecticut taxes corporations pursuant to a "piggy-back" system whereby Federal taxable income serves as the State taxable income base. The Commissioner and Consolidated (a Connecticut corporation and an accrual method taxpayer) reached an agreement in 1983 that part of Consolidated's 1976 Federal deduction for officers' salaries should be disallowed. The resulting increase in Consolidated's 1976 Federal taxable income from the 1983 settlement gave rise to an additional Connecticut corporation business tax liability, which Consolidated sought to accrue in 1976. Held, Consolidated may not…
1Opinion of the Court
Consolidated Industries, Inc., et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent
Consolidated Industries, Inc. v. Commissioner
Docket Nos. 20523-80, 20524-80, 20526-80
United States Tax Court
82 T.C. 477; 1984 U.S. Tax Ct. LEXIS 94; 82 T.C. No. 35;
March 15, 1984, Filed
Decisions will be entered under Rule 155.
Connecticut taxes corporations pursuant to a "piggy-back" system whereby Federal taxable income serves as the State taxable income base. The Commissioner and Consolidated (a Connecticut corporation and an accrual method taxpayer) reached an agreement in 1983 that part of…
2Cases cited14 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
- Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
- United States v. Consolidated Edison Co. of NYSupreme Court of the United States · 1961
- Chesbro v. CommissionerUnited States Tax Court · 1953
9 more not listed; retrieve them via the Exa API.