Arnold, Constable Corp. v. Commissioner

Board of Tax Appeals

Arnold, Constable Corp. v. Commissioner

26 B.T.A. 1427

CourtUnited States Board of Tax Appeals

DecidedOctober 31, 1932

DocketDocket No. 47847

StatusPublished

This text of 26 B.T.A. 1427 (Arnold, Constable Corp. v. Commissioner) is published on Counsel Stack Legal Research, covering United States Board of Tax Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Arnold, Constable Corp. v. Commissioner, 26 B.T.A. 1427 (bta 1932).

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Opinions

[1429]*1429OPINION.

GoodRich:

We have held heretofore that, for the purpose of applying a net loss sustained by a corporation prior to affiliation to income earned thereafter, the periods of the calendar or fiscal year before and after the affiliation of previously existing corporations occurs, under the provisions of section 200 (a) of the Revenue A-ct of 1924, each constitute a “taxable year.” Weissberger Moving & Storage Co., 26 B. T. A. 1375. The pertinent parts of that section have been unchanged by the Revenue Acts of 1926 and 1928 which are applicable to this case.

Reviewed by the Board.

Judgment will be entered for the respondent.

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[1429]*1429OPINION.

GoodRich:

We have held heretofore that, for the purpose of applying a net loss sustained by a corporation prior to affiliation to income earned thereafter, the periods of the calendar or fiscal year before and after the affiliation of previously existing corporations occurs, under the provisions of section 200 (a) of the Revenue A-ct of 1924, each constitute a “taxable year.” Weissberger Moving & Storage Co., 26 B. T. A. 1375. The pertinent parts of that section have been unchanged by the Revenue Acts of 1926 and 1928 which are applicable to this case.

Reviewed by the Board.

Judgment will be entered for the respondent.

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26 B.T.A. 1427, Counsel Stack Legal Research, https://law.counselstack.com/opinion/arnold-constable-corp-v-commissioner-bta-1932.