Electronic Sensing Products, Inc. v. Commissioner
United States Tax Court
Petitioner organized a wholly owned subsidiary (H) on Oct. 6, 1972, and another wholly owned subsidiary (D) on Feb. 15, 1973. Petitioner and H filed separate income tax returns for their respective taxable years ended Oct. 31, 1972 (Nov. 1, 1971, to Oct. 31, 1972, for petitioner and Oct. 6, 1972, to Oct. 31, 1972, for H). Petitioner and H and D filed a consolidated return for the taxable year ended Oct. 31, 1973, reflecting a net operating loss attributable to all three…
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Petitioner organized a wholly owned subsidiary (H) on Oct. 6, 1972, and another wholly owned subsidiary (D) on Feb. 15, 1973. Petitioner and H filed separate income tax returns for their respective taxable years ended Oct. 31, 1972 (Nov. 1, 1971, to Oct. 31, 1972, for petitioner and Oct. 6, 1972, to Oct. 31, 1972, for H). Petitioner and H and D filed a consolidated return for the taxable year ended Oct. 31, 1973, reflecting a net operating loss attributable to all three corporations. Because of losses incurred by petitioner for its taxable year ended Oct. 31, 1968, through its taxable year…
1Opinion of the Court
Electronic Sensing Products, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Electronic Sensing Products, Inc. v. Commissioner
Docket No. 5112-76
United States Tax Court
69 T.C. 276; 1977 U.S. Tax Ct. LEXIS 22;
November 22, 1977, Filed
Petitioner organized a wholly owned subsidiary (H) on Oct. 6, 1972, and another wholly owned subsidiary (D) on Feb. 15, 1973. Petitioner and H filed separate income tax returns for their respective taxable years ended Oct. 31, 1972 (Nov. 1, 1971, to Oct. 31, 1972, for petitioner and Oct. 6, 1972, to Oct. 31, 1972, for H). Petitioner and H and D filed…
2Cases cited8 opinions
- Interstate Transit Lines v. CommissionerSupreme Court of the United States · 1943
- National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
- Woolford Realty Co. v. RoseSupreme Court of the United States · 1932
- Trinco Industries, Inc. v. CommissionerUnited States Tax Court · 1954
- American Trans-Ocean Navigation Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1956
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