Legal Opinion

Ohio & Big Sandy Coal Co. v. Commissioner

United States Board of Tax Appeals

Decided February 8, 1929No. Docket No. 7888Published

1. March 1, 1913, value of certain coal lands determined. 2. Where corporations were affiliated for excess-profits-tax purposes for a fractional part of 1917, but occupy a nonaffiliated status for the remainder of the year, the income tax may not be computed upon the basis of such fractional period, but must be computed upon the basis of a full taxable year. 3. In computing the excess-profits credit for a consolidated group for 1917 only one specific exemption of $3,000 is…

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1. March 1, 1913, value of certain coal lands determined. 2. Where corporations were affiliated for excess-profits-tax purposes for a fractional part of 1917, but occupy a nonaffiliated status for the remainder of the year, the income tax may not be computed upon the basis of such fractional period, but must be computed upon the basis of a full taxable year. 3. In computing the excess-profits credit for a consolidated group for 1917 only one specific exemption of $3,000 is allowable and not an exemption of $3,000 for each corporation which is a member of the group. 4. The provision in section…

1Opinion of the Court

TRUSTEES FOR OHIO & BIG SANDY COAL CO., UNITED THACKER COAL CO., AND FEDERAL GAS, OIL & COAL CO., PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Ohio & Big Sandy Coal Co. v. Commissioner

Docket No. 7888.

United States Board of Tax Appeals

15 B.T.A. 273; 1929 BTA LEXIS 2883;

February 8, 1929, Promulgated

1. March 1, 1913, value of certain coal lands determined.

2. Where corporations were affiliated for excess-profits-tax purposes for a fractional part of 1917, but occupy a nonaffiliated status for the remainder of the year, the income tax may not be computed upon the basis of such…

2Cases cited10 opinions

  1. Dowagiac Manufacturing Co. v. Minnesota Moline Plow Co.Supreme Court of the United States · 1915
  2. United Fuel Gas Co. v. Railroad CommissionSupreme Court of the United States · 1929
  3. Willcuts v. Milton Dairy Co.Supreme Court of the United States · 1927
  4. Farmers Deposit Nat'l Bank v. CommissionerUnited States Board of Tax Appeals · 1926
  5. Christie v. PattonSupreme Court of Alabama · 1906

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