Neal v. United States

FINDINGS OF FACT AND CONCLUSIONS OF LAW

HALL, District Judge.

Upon consideration of the evidence introduced by the parties in this proceeding, both oral and documentary, in addition to the pleadings and other documents filed in this matter, the Court makes. the following Findings of Fact and Conclusions of Law:

FINDINGS OF FACT

Introductory Statement

I

The sole issue in this case involves the application of Section 1374(c) (2) of the Internal Revenue Code of 1954 to an operating loss sustained by Neal’s Die Shop, Inc., in 1963

IT

Neal’s Die Shop, Inc., is a corporation which, in 1958, elected to be…