Cunningham Group v. Commissioner of Revenue Serv.

The plaintiff, Cunningham Group, Inc., appeals a determination by the defendant commissioner of revenue services (commissioner) disallowing a net operating carryover loss on the plaintiff's state corporation business tax returns for 1988, 1989 and 1990. General Statutes §12-213, et seq. The court finds for the plaintiff.

The parties submitted a written stipulation of facts and accompanying documents. Those facts pertinent to this appeal are as follows. On March 31, 1988, Cunningham Information Systems, Inc. (Cunningham Information) merged into Cunningham Reporting Associates, Inc. (Cunningham…