Fajardo Sugar Co. v. Commissioner
United States Board of Tax Appeals
1. A net loss for a period ended July 31, 1919, there being no income for the year ended July 31, 1920, may not be deducted in computing taxable income for the year ended July 31, 1921. 2. Under the Revenue Act of 1921, expenditures made by a foreign corporation in conducting its business are deductible in computing its taxable income from sources within the United States only when allocable to the production of income from sources within the United States or where a ratable…
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1. A net loss for a period ended July 31, 1919, there being no income for the year ended July 31, 1920, may not be deducted in computing taxable income for the year ended July 31, 1921. 2. Under the Revenue Act of 1921, expenditures made by a foreign corporation in conducting its business are deductible in computing its taxable income from sources within the United States only when allocable to the production of income from sources within the United States or where a ratable part of general expenditures is apportioned to income from sources within the United States. Where the Commissioner has…
1Opinion of the Court
*984OPINION.
Phillips:
Since petitioner’s fiscal year began in 1920 and ended July 31, 1921, its income for that year is taxable in the manner provided by section 205(a) of the Revenue Act of 1921 which, so far as pertinent here, reads as follows:. That if a taxpayer makes return for a fiscal year, beginning in 1920 and 'ending in 1921, his tax under this title for the taxable year 1921 shall be the sum of: (1) the same proportion of a tax for the entire period computed under Title II of the Revenue Act of 1918 at the rates for the calendar year 1920 which the portion of such period falling within…
2Cases cited6 opinions
- Smith v. Kansas City Title & Trust Co.Supreme Court of the United States · 1921
- Aldrich v. Chemical National BankSupreme Court of the United States · 1900
- Western National Bank v. ArmstrongSupreme Court of the United States · 1894
- Auten v. United States Nat. Bank of NYSupreme Court of the United States · 1899
- Oulton v. Savings InstitutionSupreme Court of the United States · 1873
1 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Balfour, Williamson & Co. v. CommissionerUnited States Tax Court · 1943
- Estate of Slutsky v. CommissionerUnited States Tax Court · 1983
- Fajardo Sugar Co. v. CommissionerUnited States Board of Tax Appeals · 1930