Amorient, Inc. v. Commissioner
United States Tax Court
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…
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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
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Strong v. CommissionerUnited States Tax Court · 1976
- Trinco Industries, Inc. v. CommissionerUnited States Tax Court · 1954
- Electronic Sensing Products, Inc. v. CommissionerUnited States Tax Court · 1977
- J. A. Tobin Constr. Co. v. CommissionerUnited States Tax Court · 1985
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