Ambac Industries, Inc. v. Commissioner
United States Tax Court
P and S joined in filing consolidated income tax returns for 1964 and 1965. S sustained net operating losses in 1964 and 1965, and these losses were used to offset the separate taxable income of P in each of the 2 years.
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P and S joined in filing consolidated income tax returns for 1964 and 1965. S sustained net operating losses in 1964 and 1965, and these losses were used to offset the separate taxable income of P in each of the 2 years. S dissolved in 1965 after making liquidating distributions to P. Held, for the purpose of computing P's loss on the worthlessness of the stock and debt of S, P's basis in such stock and debt must be reduced by the sum of S's net operating losses in 1964 and 1965. Sec. 1.1502-34A(b)(2)(i), Income Tax Regs.Henry C. Beck Builders, Inc., 41 T.C. 616, 629-633 (1964), distinguished.
1Opinion of the Court
Ambac Industries, Inc., Formerly Known as American Bosch Arma Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent
Ambac Industries, Inc. v. Commissioner
Docket No. 1665-70
United States Tax Court
59 T.C. 670; 1973 U.S. Tax Ct. LEXIS 172; 59 T.C. No. 66;
February 13, 1973, Filed
Decision will be entered for the respondent.
P and S joined in filing consolidated income tax returns for 1964 and 1965. S sustained net operating losses in 1964 and 1965, and these losses were used to offset the separate taxable income of P in each of the 2 years. S dissolved in 1965 after making…
2Cases cited14 opinions
- United States v. Skelly Oil Co.Supreme Court of the United States · 1969
- Charles Ilfeld Co. v. HernandezSupreme Court of the United States · 1934
- Henry C. Beck Builders, Inc. v. CommissionerUnited States Tax Court · 1964
- McLaughlin v. Pacific Lumber Co.Supreme Court of the United States · 1934
- Bush Terminal Bldgs. Co. v. CommissionerUnited States Tax Court · 1946
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