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ISLAND PETROLEUM CO. v. COMMISSIONER OF INTERNAL REV.

No. 3242.

57 F.2d 992 (1932)

ISLAND PETROLEUM CO. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fourth Circuit.

April 12, 1932.

Attorney(s) appearing for the Case

J. Kemp Bartlett, of Baltimore, Md. (William M. Williams and John R. Yates, both of Washington, D. C., on the brief), for petitioner.

Morton K. Rothschild, Sp. Asst. to Atty. Gen. (G. A. Youngquist, Asst. Atty. Gen., Sewall Key, Sp. Asst. to Atty. Gen., and C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, and Frank M. Thompson, Sp. Atty., Bureau of Internal Revenue, both of Washington, D. C., on the brief), for respondent.

Before PARKER, NORTHCOTT, and SOPER, Circuit Judges.

PARKER, Circuit Judge.

This is a petition by the Island Petroleum Company, a Delaware corporation, to review a decision of the Board of Tax Appeals. The questions presented by the petition are: (1) Whether petitioner was entitled to file a consolidated income tax return for the year ending April 30, 1920, with four Texas corporations, 60 per cent. of whose stock it owned; and (2), if not, whether it was entitled to deduct from income, as an expense or loss of the...

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