Glover Packing Company of Texas v. The United States

WHITAKER, Judge.

This is a suit for the refund of income taxes based on plaintiff’s claim that it is entitled to deduct from its 1957 income losses sustained in prior years. It is entitled to do so unless section 382(a) of the Internal Revenue Code of 1954 1 pro Mbits it. So far as this case is concerned that section provides that if the person who owned the greatest percentage of the market value of plaintiff’s stock at the end of 1957 had acquired it by purchase during the current year or the prior year, and if the kind of business carried on by the corporation changed after such…