Federal Cement Title Co. v. Commissioner
United States Tax Court
The petitioner sustained net operating losses in the taxable years 1950, 1951, and 1952 in the conduct, in 15 States on or near the east coast of the United States, of a cement tile roofing business utilizing a patented Swiss process.
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The petitioner sustained net operating losses in the taxable years 1950, 1951, and 1952 in the conduct, in 15 States on or near the east coast of the United States, of a cement tile roofing business utilizing a patented Swiss process. In 1953, pursuant to agreements with an unrelated group, the petitioner's stockholders sold their stock to such unrelated group and the petitioner simultaneously transferred its land and building, fixed assets, and inventories to the selling stockholders, retaining the patent rights in the Swiss process in the United States other than in the 15 East Coast…
1Opinion of the Court
Atkins, Judge:
The respondent determined deficiencies in income tax for the taxable years 1953 to 1957, inclusive, in the respective amounts of $196,002.76, $288,146.03, $11,505.26, $111,762.82, and $14,085.74.
Certain issues have been disposed of by stipulation of the parties. The issues remaining for decision are (1) whether the petitioner, which sustained net operating losses in the calendar years 1950, 1951, and 1952 in the conduct of a cement roofing tile business, may carry over and deduct such losses from income earned by it in the years 1953 through 1956 in the conduct of a cement…
2Cases cited19 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
- McWilliams v. CommissionerSupreme Court of the United States · 1947
- Heil Beauty Supplies, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1952
- Ingle Coal Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1949
14 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- H. F. Ramsey Co. v. CommissionerUnited States Tax Court · 1965
- Beckett v. CommissionerUnited States Tax Court · 1963
- Clarksdale Rubber Co. v. CommissionerUnited States Tax Court · 1965
- Tracinda Corp. v. CommissionerUnited States Tax Court · 1998
- Euclid-Tennessee, Inc. v. CommissionerUnited States Tax Court · 1964
11 more not listed; retrieve them via the Exa API.