Kent v. Commissioner
United States Tax Court
Net Operating Loss Deduction for 1953 Based on Net Operating Loss Carryback From 1955 -- Applicable Law. -- Net operating loss for 1955, computed and carried back to 1953 under section 172 of the 1954 Code, must be reduced by adjustments provided in section 122(d) of the 1939 Code in computing the amount of the net operating loss deduction allowable for 1953. The net operating loss deduction for 1953 must be computed under section 122(c) of the 1939 Code even though only…
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Net Operating Loss Deduction for 1953 Based on Net Operating Loss Carryback From 1955 -- Applicable Law. -- Net operating loss for 1955, computed and carried back to 1953 under section 172 of the 1954 Code, must be reduced by adjustments provided in section 122(d) of the 1939 Code in computing the amount of the net operating loss deduction allowable for 1953. The net operating loss deduction for 1953 must be computed under section 122(c) of the 1939 Code even though only amount to be included therein is the net operating loss carryback from 1955.
1Opinion of the Court
Herbert J. Kent and Emily P. Kent, Husband and Wife, Petitioners, v. Commissioner of Internal Revenue, Respondent
Kent v. Commissioner
Docket No. 71564
United States Tax Court
35 T.C. 30; 1960 U.S. Tax Ct. LEXIS 54;
October 10, 1960, Filed
Decision will be entered for the respondent.
Net Operating Loss Deduction for 1953 Based on Net Operating Loss Carryback From 1955 -- Applicable Law. -- Net operating loss for 1955, computed and carried back to 1953 under section 172 of the 1954 Code, must be reduced by adjustments provided in section 122(d) of the 1939 Code in computing the amount of the net…
2Cases cited4 opinions
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Reo Motors, Inc. v. CommissionerSupreme Court of the United States · 1950
- Kent v. CommissionerUnited States Tax Court · 1960
- Cambria Collieries Co. v. CommissionerUnited States Tax Court · 1948