Legal Opinion

Beneficial Industrial Loan Corp. v. Commissioner

United States Tax Court

Decided October 23, 1946No. Docket No. 7629Published

1. Petitioner and its 250 or more subsidiaries elected under section 730 of the Internal Revenue Code to file a consolidated excess profits tax return for the calendar year 1940. Most of the subsidiaries were small loan companies, which kept books and reported income on the basis of cash receipts and disbursements.

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1. Petitioner and its 250 or more subsidiaries elected under section 730 of the Internal Revenue Code to file a consolidated excess profits tax return for the calendar year 1940. Most of the subsidiaries were small loan companies, which kept books and reported income on the basis of cash receipts and disbursements. Two of the subsidiaries were insurance companies, which kept books and reported income on the accrual basis prescribed by section 204 of the Internal Revenue Code. During the base period years, as well as the taxable year, the insurance subsidiaries, in consideration of flat…

1Opinion of the Court

Beneficial Industrial Loan Corporation, Petitioner, v. Commissioner of Internal Revenue, Respondent

Beneficial Industrial Loan Corp. v. Commissioner

Docket No. 7629

United States Tax Court

7 T.C. 1019; 1946 U.S. Tax Ct. LEXIS 49;

October 23, 1946, Promulgated

Decision will be entered under Rule 50.

1. Petitioner and its 250 or more subsidiaries elected under section 730 of the Internal Revenue Code to file a consolidated excess profits tax return for the calendar year 1940. Most of the subsidiaries were small loan companies, which kept books and reported income on the basis of cash receipts and…

2Cases cited3 opinions

  1. Boyd-Richardson Co. v. CommissionerUnited States Tax Court · 1945
  2. J.F. Johnson Lumber Co. v. CommissionerUnited States Tax Court · 1944
  3. Beneficial Industrial Loan Corp. v. CommissionerUnited States Tax Court · 1946

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