Alabama By-Products Corp. v. Commissioner
United States Board of Tax Appeals
A corporation which suffered a net loss in 1919, prior to entering an affiliated group in 1920, is entitled to have the amount of such net loss in excess of its 1918 net income allowed as a deduction in computing net income for 1920, and the resulting deficit should be reflected in the computation of the consolidated net income for 1920. Section 204(b), Revenue Act of 1918.
1Opinion of the Court
MEMORANDUM OPINION.
Trammell :
A rehearing was had in this proceeding on November 20,1929, pursuant to motion timely filed, at which time the petitioner urged that our decision in this case is in conflict with our conclusions reached in Moore Cotton Mills Co., 17 B. T. A. 662, and that if the principles announced in the latter case were applied in the instant case, a different result would be reached.
In our former opinion in the case at bar (16 B. T. A. 1073), we said: :
Since, under the statute, each member of an affiliated group is a “ taxpayer ” and the relief granted by section 204 is given…
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