A. R. Ruppert Plumbing & Heating Co. v. Commissioner
United States Tax Court
Petitioner was incorporated September 27, 1948. It sustained large net operating losses for the fiscal years ended September 30, 1949 and 1950. On October 1, 1950, it organized a subsidiary by transferring a part of its assets to the subsidiary for all of the latter's stock.
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Petitioner was incorporated September 27, 1948. It sustained large net operating losses for the fiscal years ended September 30, 1949 and 1950. On October 1, 1950, it organized a subsidiary by transferring a part of its assets to the subsidiary for all of the latter's stock. Thereafter, the two corporations filed consolidated returns for the fiscal years ended September 30, 1951 through 1956. For the fiscal year ended September 30, 1954 (the taxable year), the group reported a net income, before any net operating loss deduction, of $ 106,898.86. It claimed a net operating loss deduction…
1Opinion of the Court
A. R. Ruppert Plumbing & Heating Co., Petitioner, v. Commissioner of Internal Revenue, Respondent
A. R. Ruppert Plumbing & Heating Co. v. Commissioner
Docket No. 84497
United States Tax Court
39 T.C. 284; 1962 U.S. Tax Ct. LEXIS 41;
October 31, 1962, Filed
Decision will be entered under Rule 50.
Petitioner was incorporated September 27, 1948. It sustained large net operating losses for the fiscal years ended September 30, 1949 and 1950. On October 1, 1950, it organized a subsidiary by transferring a part of its assets to the subsidiary for all of the latter's stock. Thereafter, the two corporations…
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- Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
- Charles Ilfeld Co. v. HernandezSupreme Court of the United States · 1934
- Helvering v. Metropolitan Edison Co.Supreme Court of the United States · 1939
- Newmarket Manufacturing Company v. United StatesCourt of Appeals for the First Circuit · 1956
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