Legal Opinion
American Bank & Trust Company v. United States
Court of Appeals for the Fifth Circuit
Decided June 18, 1964No. 20425PublishedCited by 5 opinions
1Opinion of the Court
WISDOM, Circuit Judge.
This action is a claim for refund of income taxes. The facts are stipulated. The taxpayer, the American Bank & Trust Company of Baton Rouge, Louisiana, sustained net operating losses in 1954 and 1955 which it carried back to the years 1952 and 1953. The issue is narrow: whether the net operating loss deduction must be calculated according to Section 172 of the Internal Revenue Code of 1954, as the tapayer maintains, or by Section 122 of the Internal Revenue Code of 1939, as the United States maintains. The district court held for the United States. We affirm.
The…
2Cases cited4 opinions
- Reo Motors, Inc. v. CommissionerSupreme Court of the United States · 1950
- John S. Taft and Virginia M. Taft and John Taft Electric Company, a Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1963
- Kent v. CommissionerUnited States Tax Court · 1960
- United States v. Whitney Land CompanyCourt of Appeals for the Eighth Circuit · 1963
3Cited by5 opinions
- Adler v. United StatesUnited States Court of Federal Claims · 1995
- Callanan Road Improvement Co. v. United StatesDistrict Court, N.D. New York · 1968
- Callanan Road Improvement Company v. United StatesCourt of Appeals for the Second Circuit · 1968
- Wofac Corporation v. United StatesDistrict Court, D. New Jersey · 1967
- Commercial Industries Corp. v. United StatesDistrict Court, D. New Jersey · 1967