Legal Opinion
Mutual Assurance Society of Virginia Corporation v. Commissioner of Internal Revenue
Court of Appeals for the Fourth Circuit
Decided October 18, 1974No. 74-1133PublishedCited by 9 opinions
1Opinion of the Court
WINTER, Circuit Judge:
In this appeal we must decide whether, where a net operating loss has been carried back and used in computing taxable income as a step in determining a taxpayer’s tax for an earlier year under the alternative method of taxing capital gains, the excess of the net operating loss deduction over ordinary income for the earlier year may be carried forward to a succeeding year. The Tax Court held that it could.1 Its holding is in accord with the views of the First, Eighth and Ninth Circuits;2 but from our analysis of the applicable statutes and their legislative history, we…
2Cases cited9 opinions
- Haggar Co. v. Helvering, Com'r of Internal RevenueSupreme Court of the United States · 1940
- Lone Manor Farms, Inc. v. CommissionerUnited States Tax Court · 1974
- Walter M. Weil and Adele D. Weil v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1956
- Chartier Real Estate Co. v. CommissionerUnited States Tax Court · 1969
- Chartier Real Estate Company, Inc. v. Commissioner of Internal Revenue, (Three Cases)Court of Appeals for the First Circuit · 1970
4 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- United States v. Foster Lumber Co.Supreme Court of the United States · 1976
- In the Matter of Avien, Inc., Debtor. The City of New York v. Avien, Inc.Court of Appeals for the Second Circuit · 1976
- Sidney Axelrod and Andrea Axelrod v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1975
- Georgia International Life Ins. Co. v. CommissionerUnited States Tax Court · 1983
- Georgia International Life Ins. Co. v. CommissionerUnited States Tax Court · 1983
4 more not listed; retrieve them via the Exa API.