T. Reed Vreeland and Diana D. Vreeland v. United States

JONES, Chief Judge.

This is a suit for the refund of Federal income taxes for the year 1946. The plaintiffs claim that they had a net operating loss in 1948 which they should be permitted to carry back to 1946 as a net operating loss deduction for 1946. The defendant disputes the 1948 loss.

The facts have been 'stipulated. The plaintiffs, who are husband and wife, filed a joint Federal income tax return for the year 1946 reporting net income of $23,760 and a tax liability of $7,900. 1 The plaintiffs filed separate income tax returns for 1947. Mrs. Vreeland received no capital gain and sustained…