Zanesville Inv. Co. v. Commissioner
United States Tax Court
Petitioner held the controlling interest in a corporation that successfully operated a newspaper. Its sole stockholder in September of 1955 transferred to petitioner a controlling interest in a coal mine corporation that had operated at a loss for several years and it was anticipated it would be some period of time before it would show profitable operation.
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Petitioner held the controlling interest in a corporation that successfully operated a newspaper. Its sole stockholder in September of 1955 transferred to petitioner a controlling interest in a coal mine corporation that had operated at a loss for several years and it was anticipated it would be some period of time before it would show profitable operation. Petitioner took the post acquisition operating losses and losses from the sale of the coal-mining company's assets in 1956 (the coal-mining company was declared a bankrupt that year) as deductions in its consolidated returns for 1955 and…
1Opinion of the Court
Mulroney, Judge:
The respondent determined deficiencies in the petitioner’s income tax as follows:
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The parties have reached agreement on several of the issues for the years 1949 through 1958 and have stipulated to that effect; the years 1949, 1950, 1951, 1958, and 1954 .are no longer involved here. The only remaining issue is whether the petitioner in its consolidated income tax returns filed for its affiliated group in 1955 and 1956 is entitled to deductions for the post acquisition losses incurred in those years by a newly acquired subsidiary, the Muskingum Coal Company, or…
2Cases cited7 opinions
- O. H. Kruse Grain & Milling v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1960
- American Pipe & Steel Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1957
- Brooks v. CommissionerUnited States Tax Court · 1961
- Elko Realty Company v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
- Elko Realty Co. v. CommissionerUnited States Tax Court · 1958
2 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- D'Arcy-MacManus & Masius, Inc. v. CommissionerUnited States Tax Court · 1975
- Fawn Fashions, Inc. v. CommissionerUnited States Tax Court · 1963
- Naeter Bros. Pub. Co. v. CommissionerUnited States Tax Court · 1964
- Cromwell Corp. v. CommissionerUnited States Tax Court · 1964
- Luke v. CommissionerUnited States Tax Court · 1964
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