Legal Opinion
Coast Quality Construction Corp. & Subsidiaries v. United States
District Court, E.D. Louisiana
Decided March 17, 1971No. Civ. A. No. 70-1072PublishedCited by 2 opinions
1Opinion of the Court
RUBIN, District Judge:
This income tax refund suit presents only one issue: whether a corporation whose stock changed hands also made a substantial change in its business at the same time and therefore lost its right to carry forward net operating losses it had previously sustained because of the provisions of IRC Section 382, 26 U.S.C. § 382. Because there was in fact no substantial change in the corporation’s business, the corporation was entitled to use its carry forward, and is entitled to the tax refund it seeks.
FACTS
Charles Kornman was the sole stockholder of four corporations engaged in…
2Cases cited7 opinions
- Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
- Commissioner of Internal Revenue v. Goodwyn Crockery CompanyCourt of Appeals for the Sixth Circuit · 1963
- Goodwyn Crockery Co. v. CommissionerUnited States Tax Court · 1961
- Euclid-Tennessee, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1965
- United States v. Northern RailroadCourt of Appeals for the First Circuit · 1964
2 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Hermes Consolidated, Inc. v. United StatesUnited States Court of Claims · 1988
- United States v. Federated Department Stores, Inc. (In Re Federated Department Stores, Inc.)District Court, S.D. Ohio · 1994