Legal Opinion
Chilivis v. Studebaker Worthington, Inc.
Court of Appeals of Georgia
Decided January 8, 1976No. 51127PublishedCited by 4 opinions
1Opinion of the Court
Marshall, Judge.
The State Revenue Commissioner appeals from a judgment in favor of the taxpayer, Studebaker Corp., allowing Studebaker to carry over and deduct on current income tax returns losses sustained by a liquidated predecessor corporation.
The facts were stipulated by the parties. In 1964, Studebaker Corp. (Old Studebaker), a Michigan corporation doing business in Georgia (and in other states) incurred a net operating loss in excess of $45 million attributable to its business of manufacturing and selling automobiles. In 1966, it sustained a net operating loss in excess of $6 million…
2Cases cited6 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- United States v. Gilbert Associates, Inc.Supreme Court of the United States · 1953
- Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
- Helvering v. Metropolitan Edison Co.Supreme Court of the United States · 1939
- Frederick Steel Co. v. CommissionerUnited States Tax Court · 1964
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3Cited by4 opinions
- Richard's Auto City, Inc. v. Director, Division of TaxationSupreme Court of New Jersey · 1995
- Macy's East, Inc. v. Commissioner of RevenueMassachusetts Supreme Judicial Court · 2004
- Richard's Auto City v. DIR., DIV. OF TAXNew Jersey Superior Court Appellate Division · 1994
- Grade a Market, Inc. v. Commissioner of Revenue ServicesConnecticut Superior Court · 1996