Lake Erie & Pittsburg Railway Co. v. Commissioner
United States Tax Court
1Opinion of the Court
OPINION.
SMITH, Judge:
The only questions for our determination are:(1) Whether the respondent acted within the scope of his authority in allocating any of the gross income of the New York Central and the Pennsylvania to the petitioner, and(2) If not, whether the modification of the original agreement of January 10, 1908, dates from January 1, 1937, or from September 27, 1939, when it was formally approved.
The provisions of section 45 of the Internal Revenue Code (the same section of the Revenue Acts of 1936 and 1938) are as follows: '
SEC. 40. ALLOCATION OF INCOME AND DEDUCTIONS.
In any case of…
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- B. Forman Co. v. CommissionerUnited States Tax Court · 1970
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