Thomas E. Snyder Sons Co. v. Commissioner
United States Tax Court
Sec. 129, I.R.C. 1939, and Sec. 269, I.R.C. 1954 -- Deductions for Loss Carryovers Denied. -- Petitioner was organized in 1949 and engaged in the business of developing and marketing cornpickers. Petitioner had net losses in 1950, 1951, 1952, and 1953. By 1953 petitioner was out of the cornpicker business. Benjamin Snyder acquired control of petitioner in 1953 by stock purchase.
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Sec. 129, I.R.C. 1939, and Sec. 269, I.R.C. 1954 -- Deductions for Loss Carryovers Denied. -- Petitioner was organized in 1949 and engaged in the business of developing and marketing cornpickers. Petitioner had net losses in 1950, 1951, 1952, and 1953. By 1953 petitioner was out of the cornpicker business. Benjamin Snyder acquired control of petitioner in 1953 by stock purchase. He transferred tank cars which he owned to petitioner for the transportation of molasses and merged into petitioner his wholly owned corporation which bought and sold molasses. Petitioner had profits in 1954, 1955,…
1Opinion of the Court
Tietjens, Judge:
The Commissioner determined the following deficiencies in income tax:
Fiscal year ended Feb. 28— Amount
1954 _ $4,128.56
1955 _ 50,870.97
1956 _ 49,875.03
The only question for decision is whether petitioner is entitled to carry over net operating losses incurred in its former farm implement business in prior years against its subsequent earnings from a different type of business not owned at the time of the losses.
FINDINGS OF FACT.
The stipulated facts are so found and the stipulation together with the exhibits attached thereto are included herein by reference.
Petitioner is an…
Also in this document: Concurrence.
2Cases cited7 opinions
- Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
- Mill Ridge Coal Company v. George D. Patterson, District Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1959
- Coastal Oil Storage Company, and v. Commissioner of Internal Revenue, AndCourt of Appeals for the Fourth Circuit · 1957
- Commissioner of Internal Revenue v. British Motor Car Distributors, Ltd., a CorporationCourt of Appeals for the Ninth Circuit · 1960
- British Motor Car Distributors, Ltd. v. CommissionerUnited States Tax Court · 1958
2 more not listed; retrieve them via the Exa API.
3Cited by52 opinions
- Ach v. CommissionerUnited States Tax Court · 1964
- Bobsee Corporation v. United StatesCourt of Appeals for the Fifth Circuit · 1969
- Thomas E. Snyder Sons Co. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1961
- Bush Hog Mfg. Co. v. CommissionerUnited States Tax Court · 1964
- Urban Redevelopment Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1961
47 more not listed; retrieve them via the Exa API.