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BOOTH FISHERIES CO. v. COMMISSIONER OF INTERNAL REVENUE

No. 5683.

84 F.2d 49 (1936)

BOOTH FISHERIES CO. (OHIO) et al. v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Seventh Circuit.

June 4, 1936.

Attorney(s) appearing for the Case

John E. Hughes, of Chicago, Ill., for petitioners.

Robert H. Jackson, Asst. Atty. Gen., and Sewall Key and Berryman Green, Sp. Assts. to Atty. Gen., and Morton K. Rothschild, of Washington, D. C., for respondent.

Before SPARKS and ALSCHULER, Circuit Judges, and BRIGGLE, District Judge.

BRIGGLE, District Judge.

Petitioners and various other affiliated corporations filed through the parent corporation a consolidated tax return for the fiscal and taxable year ending April 30, 1930. The Commissioner determined a deficiency of $1,958.47, due to the disallowance by the Commissioner of certain losses of the Canadian subsidiaries of petitioners. The parent and some of the affiliated companies later became involved in bankruptcy and receivership proceedings...

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