Alumax Inc. and Consolidated Subsidiaries - Page 105

                                       - 97 -                                         
          group.  Joint Committee report, supra at 66.  After considering             
          the Joint Committee report, the House of Representatives (House)            
          in its bill that Congress considered in connection with passage             
          of the 1928 Act decided to deny the privilege of filing consoli-            
          dated returns after taxable year 1928, thereby compelling all               
          corporations to file separate returns.  See H.R. 1, 70th Cong.,             
          1st Sess. sec. 141 (1927); see also H. Rept. 2, 70th Cong. 1st              
          Sess. (1927), 1939-1 C.B. (Part 2) 384, 397.                                
               The Senate Finance Committee was not convinced that elimina-           
          tion of the privilege of filing consolidated returns was an                 
          appropriate solution to the wide range of problems and potential            
          abuses to which the Joint Committee report alluded that had                 
          emerged in the administration and interpretation of the consoli-            
          dated return provisions.  Instead, the Senate Finance Committee             
          recommended retention of the consolidated return provisions but             
          coupled such retention with provisions authorizing the Commis-              
          sioner, with the approval of the Secretary of the Treasury                  
          (Secretary), to promulgate special regulations that would deal              
          with the types of problems and potential abuses raised by the               
          Joint Committee report.  The Senate Finance Committee stated in             
          pertinent part:                                                             
                    Many difficult and complicated problems * * * have                
               arisen in the administration of the provisions permit-                 
               ting the filing of consolidated returns.  It is, obvi-                 
               ously, of utmost importance that these questions be                    
               answered with certainty and a definite rule be pre-                    
               scribed.  Frequently, the particular policy is compara-                
               tively immaterial, so long as the rule to be applied is                
               known.  The committee believes it to be impracticable                  



Page:  Previous  87  88  89  90  91  92  93  94  95  96  97  98  99  100  101  102  103  104  105  106  Next

Last modified: May 25, 2011