H. F. Ramsey Co. v. Commissioner
United States Tax Court
Petitioner was in the road construction business and had suffered operating losses prior to and in 1956. In the middle of 1956 petitioner, under an agreement with its bonding company, curtailed its activities, took on no new business thereafter, and sold most of its equipment to complete its obligations under existing contracts and liquidate its debts. In December 1957 all of petitioner's stock was acquired by purchase by T and B who were also in the construction business.
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Petitioner was in the road construction business and had suffered operating losses prior to and in 1956. In the middle of 1956 petitioner, under an agreement with its bonding company, curtailed its activities, took on no new business thereafter, and sold most of its equipment to complete its obligations under existing contracts and liquidate its debts. In December 1957 all of petitioner's stock was acquired by purchase by T and B who were also in the construction business. T and B thereafter operated petitioner in the road construction business at a profit. Held, petitioner continued to carry…
1Opinion of the Court
DeeNNek, Judge:
Respondent determined deficiencies in petitioner’s income tax for the taxable years 1958 and 1959 in the respective amounts of $34,416.70 and $16,127.37.
The only issue for decision is whether petitioner, all of whose issued and outstanding stock was acquired by Baxter H. Taylor and Sam H. Bushnell in December 1957, is entitled to net operating loss deductions in 1958 and 1959 comprised of net operating loss carryovers from years prior to 1957.
There is no real dispute between the parties with respect to the evidentiary facts important to a decision of this issue, except for the…
2Cases cited19 opinions
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- J. G. Dudley Company, Incorporated (Formerly Headen Hosiery Mills, Incorporated) v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1962
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