Legal Opinion

Moore, Inc. v. Commissioner

United States Tax Court

Decided November 30, 1944No. Docket No. 3799PublishedCited by 11 opinions

A corporate net operating loss of the calendar year ended December 31, 1941, for determining the carry-over as a net operating loss deduction for the calendar year 1942, is to be determined under section 122 (d) (4) of the Internal Revenue Code, as amended by section 150 (e) of the Revenue Act of 1942.

1Opinion of the Court

OPINION.

Leech, Judge-.

This proceeding seeks a redetermination of a deficiency in income tax for the calendar year 1942 in the sum of $496.61.

The sole issue is whether the net operating loss for determining the carry-over from the calendar year 1941 to the calendar year 1942'is to be computed under section 122 (d) (4) of the Internal Revenue Code as amended by section 150 (e) of the Revenue Act of 1942, or under section 122 (d) (4) of the Code as effective in the year prior to such amendment.

The facts are found as stipulated and. so far as material, are as follows:

Petitioner is a corporation…

2Cited by11 opinions

  1. Reo Motors, Inc. v. CommissionerUnited States Tax Court · 1947
  2. Commissioner v. Moore, Inc.Court of Appeals for the Fifth Circuit · 1945
  3. Reo Motors, Inc. v. CommissionerCourt of Appeals for the Sixth Circuit · 1948
  4. Community Public Service Co. v. CommissionerUnited States Tax Court · 1949
  5. Birch Ranch & Oil Co. v. CommissionerUnited States Tax Court · 1948

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