Texas Land & Mortg. Co. v. Commissioner
United States Board of Tax Appeals
In determining the ratable part of the expenses, losses, and other deductions of a foreign corporation which can not definitely be allocated to some item or class of gross income for the purpose of computing the net income from sources within the United States, held that the gross income from all sources is not to be reduced by the amount of total losses from the sale of securities and that the gross income from sources within the United States is not to be reduced by the…
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In determining the ratable part of the expenses, losses, and other deductions of a foreign corporation which can not definitely be allocated to some item or class of gross income for the purpose of computing the net income from sources within the United States, held that the gross income from all sources is not to be reduced by the amount of total losses from the sale of securities and that the gross income from sources within the United States is not to be reduced by the amount of losses from the sale of securities in the United States.
1Opinion of the Court
OPINION.
TRAMMeul i
This proceeding is for the redetermination of deficiencies in income tax of $250.66 and $984.19 for the fiscal years ended March 31, 1930, and March 31, 1931, respectively. The only matter in controversy is whether in determining the petitioner’s taxable income for each of the years in question the respondent *862correctly determined the proportion of petitioner’s expenses, losses, and other deductions which could not definitely be allocated to some item or class of gross income for the respective years. All other issues were conceded by the respondent. The proceeding was…
2Cases cited3 opinions
- National Lead Co. v. United StatesSupreme Court of the United States · 1920
- United States v. G. Falk & BrotherSupreme Court of the United States · 1907
- Oil Shares, Inc. v. CommissionerUnited States Board of Tax Appeals · 1934
3Cited by1 opinion
- Texas Land & Mortg. Co. v. CommissionerUnited States Board of Tax Appeals · 1934