Legal Opinion

Brooklyn Beading & Novelty Co. v. Commissioner

United States Board of Tax Appeals

Decided December 6, 1929No. Docket No. 22254Published

The evidence fails to show that petitioner and another corporation were deprived of their right to file consolidated returns for the year 1922. The fact that prior to the making of their returns for 1923 the Commissioner determined that said corporations were affiliated during the years 1918 to 1920 can not be held to be a grant of permission to them to change the basis of their returns for 1922 and 1923 from separate to consolidated.

1Opinion of the Court

BROOKLYN BEADING & NOVELTY CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Brooklyn Beading & Novelty Co. v. Commissioner

Docket No. 22254.

United States Board of Tax Appeals

18 B.T.A. 450; 1929 BTA LEXIS 2046;

December 6, 1929, Promulgated

The evidence fails to show that petitioner and another corporation were deprived of their right to file consolidated returns for the year 1922. The fact that prior to the making of their returns for 1923 the Commissioner determined that said corporations were affiliated during the years 1918 to 1920 can not be held to be a grant of permission…

2Cases cited2 opinions

  1. B. B. Bathing Park, Inc. v. CommissionerUnited States Board of Tax Appeals · 1929
  2. Brooklyn Beading & Novelty Co. v. CommissionerUnited States Board of Tax Appeals · 1929

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