Hughes Tool Co. v. Commissioner

40 B.T.A. 963, 1939 BTA LEXIS 771
CourtUnited States Board of Tax Appeals
DecidedNovember 28, 1939
DocketDocket No. 90002.
StatusPublished
Cited by1 cases

This text of 40 B.T.A. 963 (Hughes Tool Co. 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.

Bluebook
Hughes Tool Co. v. Commissioner, 40 B.T.A. 963, 1939 BTA LEXIS 771 (bta 1939).

Opinion

[966]*966OPINION.

Aknold :

Petitioner contends that it is entitled to carry forward as a deduction from 1930 consolidated income the net loss of $728,-415.87 sustained by the Caddo Co., from January 1 to December 12, 1929, a period prior to affiliation, without adjustment for taxable income of $141,828.10 realized by the affiliated group from December 13 to December 31, 1929, for which period a consolidated return was filed. It further contends that the cost or aggregate basis of its Caddo stock was increased $2,579,881.94 by a contribution to capital of the Caddo Co. made under the following circumstances: Said amount was received by petitioner as part of a $3,000,000 dividend declared December 12, payable December 20, 1929, by the Hughes Tool Co. then a wholly owned subsidiary of petitioner, in the form of a claim of said Hughes Tool Co. against the Caddo Co., transfer of the claim to petitioner being reflected by entry on petitioner’s books December 31, 1929, and on the books of the Hughes Tool Co. January 2, 1930, which amount was charged by petitioner to “capital stock of subsidiaries”, and credited to the account of the Caddo Co. by entry on petitioner’s books on April 30, 1930, and forgiven, remitted, and canceled by resolution of petitioner’s board of directors on July 7, 1930.

Respondent contends that the cost or aggregate basis of the Caddo Co. stock is $5,000 and can not be increased by the remission or can-[967]*967collation of the claim against the Caddo Co., as a contribution to capital stock of the Caddo Co.; that article 41 (e) of Begulations 75 limits the allowable deduction to the cost or aggregate basis of the Caddo stock in the hands of petitioner and, since the consolidated net income for that portion of 1929 covered by the consolidated return was in excess of $5,000, there is no statutory net loss carryover deductible from 1930 consolidated income. Petitioner assails Commissioner’s construction and the validity of the regulation and contends that the regulation exceeds the authority conferred on the Commissioner by section 141 (b) of the Revenue Act of 1928.

Section 117 (a) of the Revenue Act of 1928 defines net loss as the excess of the deductions allowed by this title over the gross income, with certain exceptions not here material.

Section 117 (b) provides that, if for any taxable year it appears upon the production of evidence satisfactory to the Commissioner that a taxpayer has sustained a net loss, the amount thereof shall be allowed as a deduction in computing the net income of the taxpayer for the succeeding taxable year and, if such net loss is in excess of such net income, the excess shall be allowed as a deduction in computing the net income for the next succeeding taxable year under regulations prescribed by the Commissioner.

Section 141 (a) of the same act gives affiliated corporations the privilege of making a consolidated return for the taxable year 1929 or any subsequent taxable year in lieu of separate returns. Such privilege is upon the condition that all corporations which have been members of the affiliated group at any time during the taxable year for which the return is made shall consent to all the regulations under subsection (b) prescribed prior to the making of such return, and the making of a consolidated return shall be considered as such consent. In the case of a corporation which is a member of the affiliated group for a fractional part of the year the consolidated return shall include the income of such corporation for such part of the year as it is a member of the affiliated group.

Section 141 (b) of the act empowers the Commissioner, with the approval of the Secretary, to prescribe such regulations as he may deem necessary in order that the tax liability of an affiliated group making a consolidated return and of each corporation in the group, both during and after the period of affiliation, may be determined, computed, assessed, collected, and adjusted in such manner as clearly to reflect the income and to prevent avoidance of tax liability.

Section 141 (c) provides that where a consolidated return is made the tax shall be determined, computed, assessed, collected, and adjusted in accordance with the regulations under subsection (b) prescribed prior to the date on which such return is made.

[968]*968Pursuant to section 141 (b) the respondent, with the approval of the Secretary, promulgated article 41 (<?) of Regulations 75, which was in effect prior to the time the consolidated return covering the latter part of 1929 was filed. The regulation is as follows:

(c) Net Loss Sustained by Separate Corporation Prior to Consolidated, Return Period.
A net loss sustained by a corporation prior to tho date upon which its income is included in the consolidated return of an affiliated group (including any not loss sustained prior to the taxable year 1929) shall be allowed as a deduction in computing tho consolidated net income of such group in the same manner, to tho same extent,, and upon the same conditions as if the consolidated net income were the income of such corporation; but in no caso in which the affiliated status is created after January 1, 1929, will any such net loss bo allowed as a deduction in excess of the cost or the aggregate basis of the stock of such corporation owned by the members of the group.
(d) Taxable year.
Any period of less than 12 months for which either a separate return or a consolidated return is filed, under the provisions of article 33, shall be considered as a taxable year.

Under the authority of Commissioner v. General Machinery Corporation, 95 Fed. (2d) 759; Helvering v. Morgan’s, Inc., 293 U. S. 121; Palomas Land & Cattle Co. v. Commissioner, 91 Fed. (2d) 100; and Lefcourt Realty Corporation, 31 B. T. A. 978, that portion of the year for which a separate return is made and that portion of the year for which a consolidated return is made are to be considered as one taxable year, notwithstanding article 41 (d) of Regulations 75 to the contrary.

The authorities cited do not sustain petitioner’s contention that the entire net loss sustained by Caddo, Inc., for tho period in 1929 prior to affiliation should be carried over as a deduction from 1930 consolidated income unaffected by tire consolidated income realized during the affiliated period in 1929. Under section 117 (b) the net loss carry-over allowable as a deduction from consolidated income of the succeeding year is the net loss sustained for the taxable year, not for a portion of the taxable year.

Prior to the enactment of the Revenue Act of 3928 a consolidated group had no right to carry over a net loss sustained by one of the affiliates prior to tho affiliation as a deduction against income of an affiliated group. That was a privilege first granted by section 141 (a) and it was limited to corporations making consolidated returns for the taxable year 1929 and thereafter.

Petitioner and Caddo could have filed separate returns had they so desired. Petitioner, having elected to file a consolidated return for that portion of 3929 during affiliation and for 1930, consented to the regulations prescribed and was bound thereby. Ilfeld Co. v. Hernandez,

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Related

Hughes Tool Co. v. Commissioner
40 B.T.A. 963 (Board of Tax Appeals, 1939)

Cite This Page — Counsel Stack

Bluebook (online)
40 B.T.A. 963, 1939 BTA LEXIS 771, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hughes-tool-co-v-commissioner-bta-1939.