Seaboard Commercial Corp. v. Commissioner
United States Tax Court
1. Judgment in a prior proceeding which established the value of the closing inventory of a predecessor taxpayer, held, to estop the parties from litigating issues involving items of the same inventory for the opening of the following year. 2. Net operating losses incurred by a subsidiary corporation during previous affiliation with another corporate group, and properly included in prior consolidated returns filed by earlier affiliated corporations, held, not available as a…
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1. Judgment in a prior proceeding which established the value of the closing inventory of a predecessor taxpayer, held, to estop the parties from litigating issues involving items of the same inventory for the opening of the following year. 2. Net operating losses incurred by a subsidiary corporation during previous affiliation with another corporate group, and properly included in prior consolidated returns filed by earlier affiliated corporations, held, not available as a carryover in consolidated returns filed for the current parent and its affiliated group. 3. Respondent's disallowances…
1Opinion of the Court
Seaboard Commercial Corporation and Subsidiary Companies, Petitioner, v. Commissioner of Internal Revenue, Respondent. Coastal Machine Works, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent
Seaboard Commercial Corp. v. Commissioner
Docket Nos. 32857, 32858, 32859
United States Tax Court
28 T.C. 1034; 1957 U.S. Tax Ct. LEXIS 111;
August 26, 1957, Filed
Decisions will be entered under Rule 50.
1. Judgment in a prior proceeding which established the value of the closing inventory of a predecessor taxpayer, held, to estop the parties from litigating issues involving items of the same…
2Cases cited25 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Tait v. Western Maryland Railway Co.Supreme Court of the United States · 1933
- Halle v. CommissionerUnited States Tax Court · 1946
- Halle v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1949
- Hawkins v. GlennSupreme Court of the United States · 1889
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