Lone Manor Farms, Inc. v. Commissioner
United States Tax Court
On its income tax return for 1967, petitioner reported and paid the alternative tax under sec. 1201, I.R.C. 1954, because it was less than the regular tax under sec. 11. None of petitioner's net operating losses from 1965 and 1966 could be availed of in the computation of such alternative tax.
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On its income tax return for 1967, petitioner reported and paid the alternative tax under sec. 1201, I.R.C. 1954, because it was less than the regular tax under sec. 11. None of petitioner's net operating losses from 1965 and 1966 could be availed of in the computation of such alternative tax. Petitioner sustained additional net operating losses in 1968 and 1970. If all of petitioner's unused net operating losses through 1970 are carried to 1967 and included in its net operating loss deduction for that year, the regular tax becomes less than the alternative tax petitioner originally reported…
1Opinion of the Court
OPINION
Tannenwald, Judge:
Respondent determined a deficiency of $59,863.57 in petitioner’s income tax for the taxable year ended January 31,1969.1 The entire deficiency arises from respondent’s disallowance of the net operating loss deduction petitioner claims for that year.
The facts of the case have been stipulated.
Petitioner is a Delaware corporation engaged in the business of farming. Its principal place of business was in Middletown, Del., at the time the petition was filed in this case. Petitioner filed its Federal income tax return for 1969 with the Internal Revenue Service Center at…
2Cases cited21 opinions
- Commissioner v. Gooch Milling & Elevator Co.Supreme Court of the United States · 1944
- Mennuto v. CommissionerUnited States Tax Court · 1971
- Carpenter v. CommissionerUnited States Tax Court · 1948
- Robbins Tire & Rubber Co. v. CommissionerUnited States Tax Court · 1969
- Abkco Industries, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1973
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- Nisselson v. Drew Industries, Inc. (In Re White Metal Rolling & Stamping Corp.)United States Bankruptcy Court, S.D. New York · 1998
- Calumet Industries, Inc. v. CommissionerUnited States Tax Court · 1990
- Hill v. CommissionerUnited States Tax Court · 1990
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