Lawyers' Bldg. Corp. v. Commissioner

35 B.T.A. 540, 1937 BTA LEXIS 862
CourtUnited States Board of Tax Appeals
DecidedFebruary 23, 1937
DocketDocket Nos. 81460, 81461, 81462, 81463, 81464.
StatusPublished
Cited by3 cases

This text of 35 B.T.A. 540 (Lawyers' Bldg. 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.

Bluebook
Lawyers' Bldg. Corp. v. Commissioner, 35 B.T.A. 540, 1937 BTA LEXIS 862 (bta 1937).

Opinion

[541]*541OPINION.

Leech:

These consolidated proceedings involve income tax deficiencies proposed by respondent for tlie calendar year 1932 against the petitioners, as follows:

Lawyers Building Corporation_ $3,406. 01
Trinity Buildings Corporation of New York_ 62, 491.15
Whitehall Improvement Corporation_ 20,335. 09
George A. Fuller Co_ 32, 249. 90
Materials Delivery Corporation_ 66.34

The facts, which were stipulated, are briefly as follows: The petitioners, during the taxable year, were 5 affiliates in a group of 15 affiliated companies whose parent was the United States Realty & Improvement Co., a New Jersey corporation. A so-called consolidated return was filed by the latter corporation for the calendar year 1932, on behalf of itself and 13 of its affiliates, including the petitioners. Each of these 13 affiliates filed the prescribed form 1122. This form constituted the authorization and consent of the subsidiary corporations included in such return by -which each subsidiary authorized the filing of such return by the parent, as agent, on its behalf, and consented to the provisions of the respondent’s Regulations 78 governing consolidated returns of affiliated corporations. The Savoy-Plaza Corporation, one of the afliliates, did not join in making the so-called consolidated return, for the reason that the corporation had been adjudicated a bankrupt on December 1, 1932, and the trustee in bankruptcy, believing, upon advice of its legal counsel, that it was required to file a separate return on behalf of the bankrupt corporation for the year 1932, refused to execute form 1122 on behalf of that corporation, and filed a separate return for that corporation for that year.

During the 11-month period ended November 30, 1932, the Savoy-Plaza Corporation suffered a net operating loss of $1,500,837.29. On that date, the liabilities of the Savoy-Plaza Corporation exceeded its book assets by the sum of $3,917,070.61. The respondent determined the tax liability of each corporation, whose income was included in the so-called consolidated return filed, on a separate basis. The correctness of that action of the respondent is the sole issue in this proceeding.

The “privilege” of affiliated corporations to have their income taxes computed upon a consolidated basis exists only by virtue of the conditional grant of that “privilege” by Congress. And, as this Board said in Smith Paper Co., 31 B. T. A. 28; affd., 78 Fed. (2d) 163; certiorari denied, 296 U. S. 627: “* * * petitioners, to enjoy its advantages, must bring themselves clearly within the specified conditions precedent to its grant. Rock Island, A. & L. R. Co. v. United States, 254 U. S. 141.”

[542]*542The Revenue Act of 1932 is controlling here. This statute, in so far as material at this point, is quoted in the margin.1 By section 141 (a) of that act, such a privilege was extended to affiliated corporations. Under the authority granted by that statute, the respondent promulgated Regulations 78, the material provisions of which appear in the margin.2 The ■ action of the respondent is [543]*543premised particularly upon article 18, which provides substantially, for present purposes, that, if there has been a failure to include in the consolidated return the income of any subsidiary, or a failure to file any of the forms required bj? these regulations, the tax liability of each member of the affiliated group shall be determined upon the basis of separate returns. Clearly, the petitioners were bound by these regulations since they filed form 1122, which was their formal consent to be so bound. Here, the income of the Savoy-Plaza Corporation was not included in the return for that year filed by the remaining members of the affiliated group nor did it file form 1122, consenting to be bound by Regulations 78 and authorizing the parent corporation to make a consolidated return on its behalf for the year in question, the filing of which, under Regulations 78, was made a condition precedent to the privilege of having the income taxes of the affiliated group computed upon a consolidated basis.

It may well be true, as argued by petitioners, that the bankruptcy of the Savoy-Plaza Corporation, which occurred on December 1, 1932, left that corporation thereafter as a mere “shell” and that such “shell” could not, in fact, be affiliated with the remaining members of the affiliation. See Houghton & Dutton Co., 26 B. T. A. 52; Prosperity Co., 27 B. T. A. 28; H. Liebes & Co., 23 B. T. A. 787. However, obviously, at least for the period in 1932 preceding December 1, the elate of the bankruptcy of the Savoy-Plaza Corporation, that, corporation was a member of the affiliated group within the provisions of section 141 (d), supra,. That fact brings the Savoy-Plaza Corporation within the requirements of section 141, supra, just as effectively as though that undisputed affiliation continued' throughout the year. This is so since section 141 (a), supra, provides that “The making of a consolidated return shall be upon the condition that all the corporations which have been members of the affiliated group at any time during the taxable year for which the return is made consent to all the regulations under subsection (b) * * *; and tire making of a consolidated return shall be considered as such consent.”

Petitioners do not question the validity of the regulations. Nor do they deny, at least very emphatically, that they are controlled by [544]*544those regulations. The burden of their argument apparently is that the regulations quoted do not cover the situation presented here, where an affiliate became bankrupt during the taxable year. They argue that the respondent has construed these regulations in their effect on both the situation where the parent of an affiliated group becomes bankrupt during the taxable year (see G. C. M. 12207, C. B. XII-2) and where the subsidiary affiliate became bankrupt during such year (see G. C. M. 12208, C. B. XII-2).

In the first General Counsel’s memorandum mentioned, it was ruled that the trustee of the parent corporate bankrupt could file a consolidated return providing the requirements of Regulations 78 were met. In the second memorandum the ruling was:

Where a group of corporations is affiliated within the meaning of section 141 (d) of the Revenue Act of 1932, and a subsidiary company is in the hands of a trustee in bankruptcy or a receiver, who is operating the property or business of the company and is, therefore, required to make returns for the corporation under section 52 (a) of that Act, the income of such a subsidiary company may be included in a consolidated return for the affiliated group, provided the trustee in bankruptcy or the receiver, as the case may be, executes Form 1122 and consents to the provisions of Regulations 78 governing the making of consolidated returns.

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Related

Landy Towel & Linen Service, Inc. v. Commissioner
38 T.C. 296 (U.S. Tax Court, 1962)
Lawyers' Bldg. Corp. v. Commissioner
35 B.T.A. 540 (Board of Tax Appeals, 1937)

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Bluebook (online)
35 B.T.A. 540, 1937 BTA LEXIS 862, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lawyers-bldg-corp-v-commissioner-bta-1937.