Legal Opinion

Lawyers' Bldg. Corp. v. Commissioner

United States Board of Tax Appeals

Decided February 23, 1937No. Docket Nos. 81460, 81461, 81462, 81463, 81464Published

Petitioners, together with 10 other corporations, were affiliated. December 1, 1932, the Savoy-Plaza Corporation, a subsidiary affiliate, was adjudicated bankrupt. For the calendar year 1932, the parent of the affiliated group filed a so-called consolidated return, including the income of all affiliates except that of the Savoy-Plaza Corporation.

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Petitioners, together with 10 other corporations, were affiliated. December 1, 1932, the Savoy-Plaza Corporation, a subsidiary affiliate, was adjudicated bankrupt. For the calendar year 1932, the parent of the affiliated group filed a so-called consolidated return, including the income of all affiliates except that of the Savoy-Plaza Corporation. All such affilates filed form 1122, authorizing a consolidated return and consenting to be bound by Regulations 78. The trustee in bankruptcy of the Savoy-Plaza Corporation failed to file form 1122 because, upon advice of counsel, it believed it…

1Opinion of the Court

LAWYERS BUILDING CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

TRINITY BUILDINGS CORPORATION OF NEW YORK, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

WHITEHALL IMPROVEMENT CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

GEORGE A. FULLER COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

MATERIALS DELIVERY CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Lawyers' Bldg. Corp. v. Commissioner

Docket Nos. 81460, 81461, 81462, 81463, 81464.

United States Board of Tax Appeals

35 B.T.A. 540;…

2Cases cited6 opinions

  1. Rock Island, Arkansas & Louisiana Railroad v. United StatesSupreme Court of the United States · 1920
  2. Houghton & D. Co. v. CommissionerUnited States Board of Tax Appeals · 1932
  3. Smith Paper Co. v. CommissionerUnited States Board of Tax Appeals · 1934
  4. Fletcher American Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1935
  5. Lawyers' Bldg. Corp. v. CommissionerUnited States Board of Tax Appeals · 1937

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