Frank Ix & Sons Virginia Corp. v. Commissioner
United States Tax Court
During its taxable years ended March 31, 1953 and 1954, the petitioner operated the Cornelius mill at a loss. On September 30, 1953, in a tax-free reorganization, it acquired in exchange for stock the assets of another corporation, owned by the same interests, which had operated the Charlottesville mill at a profit. After the reorganization the petitioner continued to operate the Cornelius mill at a loss until July 22, 1954, when it terminated the operation of that mill.
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During its taxable years ended March 31, 1953 and 1954, the petitioner operated the Cornelius mill at a loss. On September 30, 1953, in a tax-free reorganization, it acquired in exchange for stock the assets of another corporation, owned by the same interests, which had operated the Charlottesville mill at a profit. After the reorganization the petitioner continued to operate the Cornelius mill at a loss until July 22, 1954, when it terminated the operation of that mill. From the time of the reorganization through its taxable years ended March 31, 1957, March 29, 1958, and March 28, 1959, it…
1Opinion of the Court
Atkins, Judge:
The respondent determined deficiencies in income tax for the taxable years ended March 31, 1957, March 29, 1958, and March 28, 1959, in the respective amounts of $84,309.62, $115,954.90, and $22,329.76.
The parties having reached agreement with respect to certain issues, the only issue remaining is whether net operating losses sustained by the petitioner for the taxable years ended March 31, 1953 and 1954, may be carried over and deducted from income earned by it in the taxable years ended March 31, 1957, March 29, 1958, and March 28, 1959, in the light of the principles of…
2Cases cited12 opinions
- Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931
- Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
- J. G. Dudley Company, Incorporated (Formerly Headen Hosiery Mills, Incorporated) v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1962
- Huyler's (Corp.) v. CommissionerUnited States Tax Court · 1962
- J. G. Dudley Co. v. CommissionerUnited States Tax Court · 1961
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3Cited by5 opinions
- United States v. BonaguroDistrict Court, E.D. New York · 1968
- Frank Ix & Sons Virginia Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1967
- Consolidated-Hammer Dry Plate & Film Co. v. CommissionerUnited States Tax Court · 1967
- Consolidated-Hammer Dry Plate & Film Co. v. CommissionerUnited States Tax Court · 1967
- Frank Ix & Sons Virginia Corp. v. CommissionerUnited States Tax Court · 1966