Temple Square Mfg. Co. v. Commissioner
United States Tax Court
Petitioner was organized in 1951 to operate an automobile agency under a franchise. It sustained net operating losses in its fiscal years ending April 30, 1952 and 1953, and on May 11, 1953, it gave up its franchise.
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Petitioner was organized in 1951 to operate an automobile agency under a franchise. It sustained net operating losses in its fiscal years ending April 30, 1952 and 1953, and on May 11, 1953, it gave up its franchise. Within the period from August 28, 1953, to the middle of September 1953, the following integrated steps took place: Petitioner's two stockholders purchased the stock of a profitable fireplace screen manufacturing and sales business owned by John E. Lydle; they dissolved the fireplace screen corporation and transferred its properties to petitioner, which then engaged in the…
1Opinion of the Court
Mulroney, Judge:
The respondent determined deficiencies in the petitioner’s income tax for the fiscal years ended April 30, 1954, 1955, and 1956, in the amounts of $8,120.17, $14,868.79, and $4,815.42, respectively. The issue is whether the petitioner is entitled to deduct certain losses in the total amount of $74,102.06 incurred in its discontinued auto sales business from its income in the operation of a new business in the fiscal years 1954,1955, and 1956.
FINDINGS OF FACT.
Some of the facts were stipulated and they are incorporated herein by this reference.
Temple Square Mfg. Co., hereinafter…
2Cases cited6 opinions
- American Pipe & Steel Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1957
- Thomas E. Snyder Sons Co. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1961
- Thomas E. Snyder Sons Co. v. CommissionerUnited States Tax Court · 1960
- Urban Redevelopment Corp. v. CommissionerUnited States Tax Court · 1960
- Elko Realty Company v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1958
1 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- Church of Scientology v. CommissionerUnited States Tax Court · 1984
- Frank Spingolo Warehouse Co. v. CommissionerUnited States Tax Court · 1961
- The Zanesville Investment Company v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1964
- Naeter Bros. Pub. Co. v. CommissionerUnited States Tax Court · 1964
- Zanesville Inv. Co. v. CommissionerUnited States Tax Court · 1962
14 more not listed; retrieve them via the Exa API.