Jupiter Corp. v. United States

OPINION

LYDON, Judge:

In this case plaintiff seeks refunds of Federal income taxes it paid for calendar years ending December 31, 1965 and December 31, 1966, plus appropriate interest as provided by law. There are two issues to be resolved in this opinion: first, whether the Internal Revenue Service (IRS) improperly disallowed plaintiff’s deduction in 1965 of certain net operating loss carryovers acquired from the 1964 liquidation of Elgin Gas and Oil Company (Elgin); and second, whether the IRS improperly classified amounts plaintiff received from a limited partnership in 1966 as the proceeds…