Goodwyn Crockery Co. v. Commissioner
United States Tax Court
Held, petitioner corporation is entitled to deduction for claimed net operating loss carryovers for the taxable years 1956, 1957, and 1958. Sections 382 and 269, I.R.C. 1954, do not apply. Held, further, amounts deducted for amortization of the cost of a 1955 management survey were correctly disallowed.
1Opinion of the Court
Mulroney, Judge:
The respondent determined deficiencies in petitioner’s income tax for the fiscal years ended June 30, 1956, 1957, and 1958, of $4,122.63, $35,748.26, and $24,803.67, respectively, and an addition to tax for 1956 under section 6651 of the Internal Revenue Code of 19541 of $1,030.65.
Petitioner had net operating losses in years prior to 1956. In 1956 petitioner’s capital stock was sold to another corporation. The questions for decision are whether petitioner is entitled to deduct operating loss carryovers in the years 1956,1957, and 1958; whether an amount paid for a management…
2Cases cited3 opinions
- Shainberg v. CommissionerUnited States Tax Court · 1959
- Baton Rouge Supply Co. v. CommissionerUnited States Tax Court · 1961
- Schlosser Bros., Inc. v. CommissionerUnited States Board of Tax Appeals · 1925
3Cited by34 opinions
- Garth v. CommissionerUnited States Tax Court · 1971
- H. F. Ramsey Co. v. CommissionerUnited States Tax Court · 1965
- Beckett v. CommissionerUnited States Tax Court · 1963
- Clarksdale Rubber Co. v. CommissionerUnited States Tax Court · 1965
- Glen Raven Mills, Inc. v. CommissionerUnited States Tax Court · 1972
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