Legal Opinion
Libson Shops, Inc., v. Koehler, District Director of Internal Revenue
Supreme Court of the United States
Decided June 24, 1957No. 64PublishedCited by 240 opinions
1Opinion of the CourtJustice Burton
The issue before us is whether, under §§23 (s) and 122 of the Internal Revenue Code of 1939, as amended, a corporation resulting from a merger of 17 separate incorporated businesses, which had filed separate income tax returns, may carry over and deduct the pre-merger net operating losses of three of its constituent corporations from the post-merger income attributable to the other businesses. We hold that such a carry-over and deduction is not permissible.
Petitioner, Libson Shops, Inc., was incorporated on January 2, 1946, under the laws of Missouri, as Libson Shops Management Corporation,…
2Cases cited16 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Manning v. Seeley Tube & Box Co.Supreme Court of the United States · 1950
- Lewyt Corp. v. CommissionerSupreme Court of the United States · 1955
- Helvering v. Metropolitan Edison Co.Supreme Court of the United States · 1939
- Standard Paving Co. v. Commissioner of Internal Revenue. Standard Paving Co. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1951
11 more not listed; retrieve them via the Exa API.
3Cited by240 opinions
- Bulova Watch Co. v. United StatesSupreme Court of the United States · 1961
- People v. ZamoraCalifornia Supreme Court · 1976
- Ach v. CommissionerUnited States Tax Court · 1964
- United Dominion Industries, Inc. v. United StatesSupreme Court of the United States · 2001
- Ballentine Motor Co. v. CommissionerUnited States Tax Court · 1962
235 more not listed; retrieve them via the Exa API.