Farmers Deposit Nat'l Bank v. Commissioner
United States Board of Tax Appeals
1. The provisions of section 240(a) of the Revenue Act of 1918, which require affiliated corporations to make a consolidated return of net income and invested capital, contemplate that the affiliated group shall be treated as existing with the attributes of a single taxpayer. 2. Shares of capital stock of any of the members of an affiliated group, outstanding in the hands of the public, are shares of capital stock of the affiliated group. 3. The sale by one member of an…
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1. The provisions of section 240(a) of the Revenue Act of 1918, which require affiliated corporations to make a consolidated return of net income and invested capital, contemplate that the affiliated group shall be treated as existing with the attributes of a single taxpayer. 2. Shares of capital stock of any of the members of an affiliated group, outstanding in the hands of the public, are shares of capital stock of the affiliated group. 3. The sale by one member of an affiliated group to other than members thereof, of shares of capital stock owned by it in another member of the group, the…
1Opinion of the Court
*521OPINION.
ARtjndell :
The record shows that the Farmers Deposit Trust Co., the Farmers Deposit Savings Bank, and the Farmers Deposit National Bank were affiliated throughout the years 1918 and 1919, and that these affiliated companies filed consolidated returns of net income and invested capital for those years. The Commissioner’s deficiency notice indicates that he regarded the affiliation as still existing throughout the year 1920, for he has computed the tax liability of the three companies on the basis of a consolidated return of net income and invested capital, and this action is not…
2Cited by21 opinions
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- RJ Reynolds Tobacco Co. v. Commissioner of Int. Rev.Court of Appeals for the Fourth Circuit · 1938
- Ohio Central Telephone Co. v. CommissionerUnited States Board of Tax Appeals · 1933
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