The Southland Corporation v. Ellis Campbell, Jr., District Director of Internal Revenue

HUTCHESON, Circuit Judge:

The Southland Corporation (South-land) claims a net operating loss deduction from its income for calendar years 1957 through 1960 inclusive. Southland is the successor, through a series of corporate manipulations not here relevant, of three now non-existent corporations: Caribbean Shipping Company (Caribbean or Loss Corporation); Cabell’s Inc. (Old Cabell’s or Profit Corporation); and the surviving corporation from the merger of these two, which retained the name Ca-bell’s Inc. (New Cabell’s or Surviving Corporation). The net operating losses upon which the carry over…