WOOLFORD REALTY CO. v. ROSE

No. 6101.

53 F.2d 821 (1931)

WOOLFORD REALTY CO., Inc., v. ROSE, Collector of Internal Revenue.

Circuit Court of Appeals, Fifth Circuit.

November 13, 1931.


Attorney(s) appearing for the Case

W. A. Sutherland, of Atlanta, Ga., for appellant.

C. P. Goree, Asst. U. S. Atty., of Atlanta, Ga., and Wright Matthews, Sp. Atty., Bureau of Internal Revenue, of Washington, D. C., for appellee.

Before BRYAN, HUTCHESON, and WALKER, Circuit Judges.


HUTCHESON, Circuit Judge.

In 1925 the Piedmont Savings Company sustained a statutory net loss of $43,478.25; in 1926 it sustained a further statutory net loss of $410.82; it was in those years unaffiliated. In 1927, appellant and the Piedmont Savings Company having become affiliated, a consolidated return for that year was filed. This return disclosed a combined net income for that year of $37,128.83 made up of appellant's net taxable income of $37,582.63 and a loss...

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