Pictorial Review Co. v. Commissioner
United States Board of Tax Appeals
1. Filing of separate return for the year 1924 by one member of affiliated group held to constitute an election under section 240, Revenue Act of 1924, even though when return was filed the Commissioner's regulations and rulings, which denied the right to affiliation, were later repudiated and affiliation was admitted.
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1. Filing of separate return for the year 1924 by one member of affiliated group held to constitute an election under section 240, Revenue Act of 1924, even though when return was filed the Commissioner's regulations and rulings, which denied the right to affiliation, were later repudiated and affiliation was admitted. Permission to change basis not having been obtained, right to include income of such member in consolidated return denied. 2. Bond discount held deductible from income on prorata basis. 3. Total accrued capital-stock-tax liability for the year 1924 held deductible from income…
1Opinion of the Court
THE PICTORIAL REVIEW COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Pictorial Review Co. v. Commissioner
Docket No. 43995.
United States Board of Tax Appeals
26 B.T.A. 472; 1932 BTA LEXIS 1305;
June 17, 1932, Promulgated
1. Filing of separate return for the year 1924 by one member of affiliated group held to constitute an election under section 240, Revenue Act of 1924, even though when return was filed the Commissioner's regulations and rulings, which denied the right to affiliation, were later repudiated and affiliation was admitted. Permission to change basis not having…
2Cases cited10 opinions
- Alameda Inv. Co. v. McLaughlinCourt of Appeals for the Ninth Circuit · 1929
- Chicago, Rock Island & Pacific Railway Co. v. CommissionerUnited States Board of Tax Appeals · 1928
- Kansas City S. Ry. v. CommissionerUnited States Board of Tax Appeals · 1929
- Lucas v. St. Louis National Baseball ClubCourt of Appeals for the Eighth Circuit · 1930
- Terminal Railroad Ass'n of St. Louis v. CommissionerUnited States Board of Tax Appeals · 1929
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