Great Lakes Hotel Co. v. Commissioner

EVAN A. EVANS, Circuit Judge.

Through this appeal petitioner seeks to set aside the decision of the Board of Tax Ap*2peals whereby it was adjudged to be indebted to the United States for income and profit taxes for the year 1920 in the sum of $28,-707.30. The taxpayer’s sole contention is that it was affiliated with H. L. Stevens & Co. and four other companies in the year 1920, within the meaning of section 240 of the Revenue Act of 1918 (40 Stat. 1081), and it is therefore entitled to offset its profits by the losses sustained by these other companies.

Even if not affiliated with all these…