Margay Oil Corp. v. Commissioner
United States Board of Tax Appeals
In April, 1925, petitioner caused a new corporation to be organized and thereafter during 1925 and 1926 the two were affiliated. Held, that in relation to 1924, for net loss purposes, the calendar year 1925 was petitioner's "succeeding taxable year" and the calendar year 1926 was the "next succeeding taxable year."
1Opinion of the Court
opinion.
Arundell:
The respondent disallowed as a deduction in computing petitioner’s net income for 1926 a net loss sustained in 1924, which with other adjustments resulted in a deficiency of $1,411.90. The only error assigned is the disallowance of the net loss deduction. The facts were stipulated and we incorporate by reference the stipulation filed as our findings of fact.
According to the stipulated facts, petitioner, a domestic corporation, was not affiliated with any other corporation during 1923 and 1924 and up to April 16, 1925. On April 8, 1925, petitioner caused to be incorporated a…
2Cited by3 opinions
- Sprague-Sells Corp. v. CommissionerUnited States Board of Tax Appeals · 1934
- Houghton & Dutton Co. v. CommissionerUnited States Board of Tax Appeals · 1932
- Margay Oil Corp. v. CommissionerUnited States Board of Tax Appeals · 1932