Legal Opinion

Amorient, Inc. v. Commissioner

United States Tax Court

Decided August 9, 1994No. Docket No. 15737-92Published

P, a corporation that had a number of subsidiary corporations, acquired an S corporation on Aug. 31, 1982. The newly acquired corporation's status as an S corporation was automatically terminated when it was acquired by P. The consolidated return for P's fiscal year ending Feb. 28, 1983, disclosed a net operating loss, a portion of which was attributable to the former S corporation for the short period Sept. 1, 1982, through Feb. 28, 1983. Held, the portion of the…

Read the full summary

P, a corporation that had a number of subsidiary corporations, acquired an S corporation on Aug. 31, 1982. The newly acquired corporation's status as an S corporation was automatically terminated when it was acquired by P. The consolidated return for P's fiscal year ending Feb. 28, 1983, disclosed a net operating loss, a portion of which was attributable to the former S corporation for the short period Sept. 1, 1982, through Feb. 28, 1983. Held, the portion of the consolidated net operating loss attributable to the former S corporation cannot be carried back to P's consolidated fiscal year…

1Opinion of the Court

Amorient, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent

Amorient, Inc. v. Commissioner

Docket No. 15737-92

United States Tax Court

103 T.C. 161; 1994 U.S. Tax Ct. LEXIS 54; 103 T.C. No. 11;

August 9, 1994, Filed

Decision will be entered under Rule 155.

P, a corporation that had a number of subsidiary corporations, acquired an S corporation on Aug. 31, 1982. The newly acquired corporation's status as an S corporation was automatically terminated when it was acquired by P. The consolidated return for P's fiscal year ending Feb. 28, 1983, disclosed a net operating loss, a portion of…

2Cases cited9 opinions

  1. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
  2. Strong v. CommissionerUnited States Tax Court · 1976
  3. Trinco Industries, Inc. v. CommissionerUnited States Tax Court · 1954
  4. Electronic Sensing Products, Inc. v. CommissionerUnited States Tax Court · 1977
  5. J. A. Tobin Constr. Co. v. CommissionerUnited States Tax Court · 1985

4 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API