Patten Fine Papers, Inc. v. Commissioner
United States Tax Court
1. Held, that petitioner may not use the net capital loss carryover of its liquidated subsidiary. 2. Held, that petitioner may not reduce the amount of its net long-term capital gains in 1949 by the amount of the net long-term capital losses sustained by its liquidated subsidiary in the taxable period January 1, 1949, to December 1, 1949. 3. Held, that petitioner, a cash basis taxpayer, in computing the amount of its personal holding company surtax liability for 1950, may…
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1. Held, that petitioner may not use the net capital loss carryover of its liquidated subsidiary. 2. Held, that petitioner may not reduce the amount of its net long-term capital gains in 1949 by the amount of the net long-term capital losses sustained by its liquidated subsidiary in the taxable period January 1, 1949, to December 1, 1949. 3. Held, that petitioner, a cash basis taxpayer, in computing the amount of its personal holding company surtax liability for 1950, may not deduct the amount of its income tax liability for 1949, which was paid in 1950, under section 505 (a) (1), 1939 Code.…
1Opinion of the Court
Patten Fine Papers, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent
Patten Fine Papers, Inc. v. Commissioner
Docket No. 56828
United States Tax Court
27 T.C. 772; 1957 U.S. Tax Ct. LEXIS 263; 27 T.C. No. 94;
February 14, 1957, Filed
Decision will be entered for the respondent.
1. Held, that petitioner may not use the net capital loss carryover of its liquidated subsidiary.
2. Held, that petitioner may not reduce the amount of its net long-term capital gains in 1949 by the amount of the net long-term capital losses sustained by its liquidated subsidiary in the taxable period January…
2Cases cited18 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Helvering v. Metropolitan Edison Co.Supreme Court of the United States · 1939
- Camp Wolters Enterprises, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1956
- Newmarket Manufacturing Company v. United StatesCourt of Appeals for the First Circuit · 1956
- Stanton Brewery v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1949
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