Legal Opinion
Euclid-Tennessee, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided December 2, 1965No. 15993PublishedCited by 13 opinions
1Opinion of the Court
O’SULLIVAN, Circuit Judge.
By its petition Euclid-Tennessee, Inc., seeks reversal of a Tax Court determination that Section 382(a) (1), of the In ternal Revenue Code of 1954, 1 *26 U.S. C.A. § 382(a) (1), prohibited its carryover of losses sustained in the brewing business to offset profits later made in the heavy equipment business after a complete change in the ownership of the taxpayer corporation. The opinion of the Tax Court is reported as Euclid-Tennessee, Inc., v. Commissioner, 41 T.C. 752 (1964).
1. The facts.
The record in the Tax Court was for the most part made from stipulated facts,…
2Cases cited5 opinions
- Commissioner v. DubersteinSupreme Court of the United States · 1960
- Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
- Commissioner of Internal Revenue v. Goodwyn Crockery CompanyCourt of Appeals for the Sixth Circuit · 1963
- Euclid-Tennessee, Inc. v. CommissionerUnited States Tax Court · 1964
- Fawick Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1965
3Cited by13 opinions
- Frederick Steel Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1967
- Exel Corporation v. United StatesCourt of Appeals for the Eighth Circuit · 1971
- Coast Quality Construction Corporation and Subsidiaries v. United StatesCourt of Appeals for the Fifth Circuit · 1972
- Six Seam Company, Inc., (73-2169), Plaintiff-Cross-Appellant (73-2170) v. United States of America, (73-2169), Defendant-Cross-Appellee (73-2170)Court of Appeals for the Sixth Circuit · 1975
- National Tea Co. v. CommissionerUnited States Tax Court · 1984
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