Legal Opinion

Urban Redevelopment Corp. v. Commissioner

United States Tax Court

Decided August 15, 1960No. Docket No. 70412PublishedCited by 46 opinions

Section 129 of the Internal Revenue Code of 1939 and Section 269 of the Internal Revenue Code of 1954. -- Deductions for loss carryovers denied. Petitioner, a New York corporation, was organized in 1949 and engaged in certain promotional work in connection with real estate development. Petitioner had net losses in 1950, 1951, and 1953. Randolph Rouse acquired control of petitioner in 1953 by stock purchase.

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Section 129 of the Internal Revenue Code of 1939 and Section 269 of the Internal Revenue Code of 1954. -- Deductions for loss carryovers denied. Petitioner, a New York corporation, was organized in 1949 and engaged in certain promotional work in connection with real estate development. Petitioner had net losses in 1950, 1951, and 1953. Randolph Rouse acquired control of petitioner in 1953 by stock purchase. He had petitioner qualify to do business in Virginia where other corporations controlled by Rouse were engaged in the construction business. Petitioner engaged in the construction business…

1Opinion of the Court

Thain, Judge:

The Commissioner determined the following deficiencies in income and excess profits taxes:

Fiscal year ended

Sept. SO— Amount

1954 _$41,654.11

1955 _ 4,294.26

The only question for decision is whether petitioner is entitled to carry over net operating losses incurred in prior years against earnings realized in its fiscal years ended September 30, 1954, and September 30, 1955.

FINDINGS OF FACT.

Some of the facts have been stipulated and are sd*found.

The petitioner is a New York corporation, organized on October 16, 1949. Its principal office was in New York City until July 14, 1953.…

2Cases cited1 opinion

  1. Thomas E. Snyder Sons Co. v. CommissionerUnited States Tax Court · 1960

3Cited by46 opinions

  1. Urban Redevelopment Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1961
  2. Baton Rouge Supply Co. v. CommissionerUnited States Tax Court · 1961
  3. J. G. Dudley Co. v. CommissionerUnited States Tax Court · 1961
  4. Beckett v. CommissionerUnited States Tax Court · 1963
  5. Frank Spingolo Warehouse Co. v. CommissionerUnited States Tax Court · 1961

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