Frederick Steel Co. v. Commissioner
United States Tax Court
1. Losses incurred by corporation in beer and ice businesses, which were discontinued in 1952, and in carrying idle real estate previously used in those businesses, may not be used as carryovers for purposes of deductions in 1954 and later years against income realized from entirely different enterprise that was transferred to the corporation in 1954. 2. B, the sole stockholder in D and controlling stockholder in F, caused the D stock to be transferred to F, which shortly…
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1. Losses incurred by corporation in beer and ice businesses, which were discontinued in 1952, and in carrying idle real estate previously used in those businesses, may not be used as carryovers for purposes of deductions in 1954 and later years against income realized from entirely different enterprise that was transferred to the corporation in 1954. 2. B, the sole stockholder in D and controlling stockholder in F, caused the D stock to be transferred to F, which shortly thereafter liquidated D, and then sold some of the assets received in the liquidation. Held: In computing the holding…
1Opinion of the Court
OPINION
Baum, Judge:
1. Loss carry-over. — -Prior to July 14, 1954, petitioner was known as Cleveland Home Brewing Co. It had sustained heavy losses in the operation of its beer business which it discontinued early in 1952. It disposed of a considerable amount of its personal property in the spring of 1952 and continued to operate its ice business until about August of 1952 when that too was discontinued. Thereafter, throughout the remainder of 1952 and 1953, it does not appear to have engaged in any activity other than attempting unsuccessfully to make some sort of profitable use or…
2Cases cited31 opinions
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3Cited by26 opinions
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