Frank Ix & Sons Virginia Corporation v. Commissioner of Internal Revenue

OPINION OF THE COURT

FREEDMAN, Circuit Judge:

Petitioner attacks the Tax Court’s dis-allowance of net operating loss carryover deductions on losses which it incurred prior to a reorganization.

The lx family, through a number of corporations, was engaged in the manufacture and sale of woven synthetic fibers. Separate corporations operated separate mills which manufactured the same types and styles of cloth within the multi-corporation structure. A central office was maintained for accounting, bookkeeping, inventory control and yarn purchasing. There ivas also provided a central sales force as…