Anbaco-Emig Corp. v. Commissioner
United States Tax Court
Petitioner, a closely held corporation engaged in the tool and die business, sold all of its machinery, fixtures, and inventory in 1958 after suffering net operating losses. It remained substantially inactive until 1960 when it purchased and began renting a loft building profitably. Relying upon excess profits tax credits cases, respondent denied claimed net operating loss carryover deductions even though the ownership of petitioner remained unchanged.
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Petitioner, a closely held corporation engaged in the tool and die business, sold all of its machinery, fixtures, and inventory in 1958 after suffering net operating losses. It remained substantially inactive until 1960 when it purchased and began renting a loft building profitably. Relying upon excess profits tax credits cases, respondent denied claimed net operating loss carryover deductions even though the ownership of petitioner remained unchanged. Held, Rev. Rul. 63-40, 1963-1 C.B. 46, and the many cases distinguishing between net operating loss deductions and excess profits tax credit…
1Opinion of the Court
Anbaco-Emig Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent
Anbaco-Emig Corp. v. Commissioner
Docket No. 4032-65
United States Tax Court
49 T.C. 100; 1967 U.S. Tax Ct. LEXIS 19;
November 22, 1967, Filed
Decision will be entered under Rule 50.
Petitioner, a closely held corporation engaged in the tool and die business, sold all of its machinery, fixtures, and inventory in 1958 after suffering net operating losses. It remained substantially inactive until 1960 when it purchased and began renting a loft building profitably. Relying upon excess profits tax credits cases,…
2Cases cited13 opinions
- Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
- Palmer v. CommissionerSupreme Court of the United States · 1937
- Weir Long Leaf Lumber Co. v. CommissionerUnited States Tax Court · 1947
- Wier Long Leaf Lumber Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1949
- Acampo Winery & Distilleries, Inc. v. CommissionerUnited States Tax Court · 1946
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