Virginia Metal Products, Inc. v. Commissioner
United States Tax Court
1. Held, petitioner has failed to show that Virginia Metal Products Corporation and its affiliated corporations are entitled to a deduction on the consolidated return for the period January 1 to December 15, 1952, of a loss claimed on the return resulting from the sale of the assets and business of one of the affiliates. 2. On September 1, 1951, Virginia Metal Products Corporation acquired all the capital stock of a corporation (Arlite Industries, Inc.) which for the 20…
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1. Held, petitioner has failed to show that Virginia Metal Products Corporation and its affiliated corporations are entitled to a deduction on the consolidated return for the period January 1 to December 15, 1952, of a loss claimed on the return resulting from the sale of the assets and business of one of the affiliates. 2. On September 1, 1951, Virginia Metal Products Corporation acquired all the capital stock of a corporation (Arlite Industries, Inc.) which for the 20 months ending August 31, 1951, had sustained net operating losses totaling $ 153,400.60. On January 2, 1952, all the assets…
1Opinion of the Court
Arundell, Judge:
Respondent determined a deficiency in income and excess profits taxes for the taxable period January 1, 1952, to December 15, 1952, in the amount of $200,967.04.
After concessions by both parties, three issues remain for our determination, as follows:
1. Are Virginia Metal Products Corporation and its affiliated companies entitled to a deduction in a consolidated return for an alleged loss from the sale of the assets and business of a corporation whose stock Virginia acquired on September 1, 1951?
2. Is the net operating loss of a corporation whose stock was acquired on September…
2Cases cited16 opinions
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
- Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
- Commissioner of Internal Revenue v. Chelsea Products, IncCourt of Appeals for the Third Circuit · 1952
- Cedar Valley Distillery, Inc. v. CommissionerUnited States Tax Court · 1951
11 more not listed; retrieve them via the Exa API.
3Cited by22 opinions
- Ach v. CommissionerUnited States Tax Court · 1964
- Thomas E. Snyder Sons Co. v. CommissionerUnited States Tax Court · 1960
- Commissioner of Internal Revenue v. Virginia Metal Products, Inc., Virginia Metal Products, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1961
- Frederick Steel Co. v. CommissionerUnited States Tax Court · 1964
- Beckett v. CommissionerUnited States Tax Court · 1963
17 more not listed; retrieve them via the Exa API.