Marwais Steel Co. v. Commissioner
United States Tax Court
A parent corporation which in earlier years used the net operating losses of its subsidiary as a basis for claiming a bad debt and worthless stock deduction is not permitted to carry over under sec. 381, I.R.C. 1954, the net operating losses of the subsidiary, which had been dissolved in the interim, since such action would enable the parent corporation to receive directly or indirectly the equivalent of a double deduction.
1Opinion of the Court
Fat, Judge:
Tbe respondent determined deficiencies in the income tax of petitioner in the amounts of $7,361.73 and $15,147.26 for the years ended January 31, 1957, and January 31, 1958, respectively.
On February 12, 1962, respondent filed an amendment to answer and claimed increased deficiencies in the amounts of $2,514.41 and $85.58 for the years ended January 31, 1957, and January 31, 1958, respectively.
The only issue left unsettled by the parties involves whether or not the petitioner may carry over and deduct the net operating losses of its subsidiary under the provisions of sections 332…
2Cases cited10 opinions
- Charles Ilfeld Co. v. HernandezSupreme Court of the United States · 1934
- Maysteel Products, Inc. v. CommissionerUnited States Tax Court · 1960
- Maysteel Products, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1961
- Chicago & NWR Co. v. Commissioner of Internal Rev.Court of Appeals for the Seventh Circuit · 1940
- Taylor-Wharton Iron & Steel Co. v. CommissionerUnited States Tax Court · 1945
5 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Miller v. CommissionerUnited States Tax Court · 1967
- Covil Insulation Co. v. CommissionerUnited States Tax Court · 1975
- Marwais Steel Company v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1965
- Estate of Joslyn v. CommissionerUnited States Tax Court · 1972
- Thrifty Oil Co. & Subsidiaries v. CommissionerUnited States Tax Court · 2012
4 more not listed; retrieve them via the Exa API.