Legal Opinion

S.F.H., Inc. v. Commissioner

United States Tax Court

Decided October 8, 1969No. Docket No. 2352-67Published

S.F.H., Inc., petitioner, for a number of years was engaged in the retail furniture business. On Aug. 11, 1961, all of petitioner's stock was sold to Merion Securities, Inc. On Oct. 27, 1961, Merion Securities, Inc., acquired control of Mount Clemens Metal Products Co., and on the same date had petitioner sell all its assets, including its installment basis accounts receivable, to Mount Clemens.

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S.F.H., Inc., petitioner, for a number of years was engaged in the retail furniture business. On Aug. 11, 1961, all of petitioner's stock was sold to Merion Securities, Inc. On Oct. 27, 1961, Merion Securities, Inc., acquired control of Mount Clemens Metal Products Co., and on the same date had petitioner sell all its assets, including its installment basis accounts receivable, to Mount Clemens. Thereafter, until its liquidation 2 years later, petitioner engaged in no trade or business. On its income tax return for the year ended June 30, 1962, petitioner claimed a net operating loss…

1Opinion of the Court

S.F.H., Inc. (Formerly Sam Fortas Housefurnishing Company, Inc.), Petitioner v. Commissioner of Internal Revenue, Respondent

S.F.H., Inc. v. Commissioner

Docket No. 2352-67

United States Tax Court

53 T.C. 28; 1969 U.S. Tax Ct. LEXIS 45;

October 8, 1969, Filed

Decision will be entered under Rule 50.

S.F.H., Inc., petitioner, for a number of years was engaged in the retail furniture business. On Aug. 11, 1961, all of petitioner's stock was sold to Merion Securities, Inc. On Oct. 27, 1961, Merion Securities, Inc., acquired control of Mount Clemens Metal Products Co., and on the same date had petitioner…

Also in this document: Concurrence; Dissent.

2Cases cited7 opinions

  1. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  2. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  3. Clarksdale Rubber Co. v. CommissionerUnited States Tax Court · 1965
  4. Fawn Fashions, Inc. v. CommissionerUnited States Tax Court · 1963
  5. Glover Packing Company of Texas v. The United StatesUnited States Court of Claims · 1964

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