Searching over 5,500,000 cases.


searching
Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.

Greif Cooperage Corp. v. Commissioner of Internal Revenue

July 10, 1936

GREIF COOPERAGE CORPORATION
v.
COMMISSIONER OF INTERNAL REVENUE



Upon Petition for Review from the United States Board of Tax Appeals.

Author: Thompson

Before DAVIS and THOMPSON, Circuit Judges, and FAKE, District Judge.

THOMPSON, Circuit Judge.

This is a petition for review of a decision of the Board of Tax Appeals. The petitioner was the parent and nonoperating company of an affiliation of twenty-three operating companies, among which were the Tuscaloosa Cooperage Company, hereinafter called Tuscaloosa, and the Sandpeeco Veneer Company, hereinafter called Sandpeeco. The petitioner acquired all of the stock of Tuscaloosa in July, 1920 at a cost of $113,100. It liquidated that company in 1925, received $35,539.97 as a liquidating dividend, and charged off $77,560.03 on its books as a loss. In August, 1920, the petitioner purchased all of the stock of Sandpeeco at a cost of $100,000 and liquidated that company in 1925. It charged off on its books its entire investment of $100,000. During the period of affiliation for which consolidated tax returns were filed, Sandpeeco's, Tuscaloosa's, and the petitioner's operating losses and taxable income were as follows:

Sandpeeco Veneer Company

Year Net Loss Taxable Income

1920 ... $16,070.24

1921 $16,654.95 ...

1922 22,114.17 ...

1923 29,832.82 ...

1924 26,494.40 ...

1925 9,317.62 ...

Total $104,413.96 ...


Buy This Entire Record For $7.95

Download the entire decision to receive the complete text, official citation,
docket number, dissents and concurrences, and footnotes for this case.

Learn more about what you receive with purchase of this case.