Legal Opinion

Weissberger Moving & Storage Co. v. Commissioner

United States Board of Tax Appeals

Decided October 27, 1932No. Docket No. 42780PublishedCited by 5 opinions

Two existing corporations became affiliated on July 1, 1924. Held, separate returns were required for the two periods of 1924 before and after the date of affiliation, and that each of said periods was a taxable year within the meaning of section 200 (a) of the Revenue Act of 1924, for the purpose of applying to petitioner's income its net loss sustained in 1922.

1Opinion of the Court

OPINION.

Goodrich :

In this proceeding, which involves the redetermination of a deficiency of $228.49 for the year 1924, but one issue is involved, namely, whether petitioner may deduct from its income for the calendar year 1924 a net loss in the amount of $1,452.90 which it sustained in 1922. We must determine whether the calendar year 1924 is the “ next succeeding taxable year ” within the meaning of the statute, or whether, under the provisions of section 200 (a) of the Revenue Act of 1924, that calendar year must be divided into two “ taxable years ” because of an affiliation which occurred…

2Cases cited1 opinion

  1. Woolford Realty Co. v. RoseSupreme Court of the United States · 1932

3Cited by5 opinions

  1. United States Trucking Corp. v. CommissionerUnited States Board of Tax Appeals · 1934
  2. Founders Assoc. v. CommissionerUnited States Board of Tax Appeals · 1933
  3. Founders Assoc. v. CommissionerUnited States Board of Tax Appeals · 1933
  4. Joseph & Feiss Co. v. CommissionerUnited States Board of Tax Appeals · 1932
  5. Weissberger Moving & Storage Co. v. CommissionerUnited States Board of Tax Appeals · 1932

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