Legal Opinion

Commonwealth Container Corp. v. Commissioner of Internal Revenue

Court of Appeals for the Third Circuit

Decided April 9, 1968No. 16960_1PublishedCited by 8 opinions

1Opinion of the Court

OPINION OF THE COURT

BIGGS, Circuit Judge.

The taxpayer, Commonwealth Container Corporation, appeals from a decision of the Tax. Court of the United States holding that there were deficiencies in income taxes for the year 1961 in the sum of $28,474.52 and for the year 1962 in the sum of $21,460.75. Jurisdiction is based on 26 U.S.C. § 7482. The only issue presented is what part of the net operating loss carryover of Tri-City Container Corp., which merged into Commonwealth on or about June 21, 1961, may be included in Commonwealth’s net operating loss deduction for the years 1961 and 1962.

Simply…

2Cases cited1 opinion

  1. Commonwealth Container Corp. v. CommissionerUnited States Tax Court · 1967

3Cited by8 opinions

  1. Wolter Construction Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1980
  2. World Service Life Insurance Company, as Corporate Successor to Stockman National Life Insurance Company v. United StatesCourt of Appeals for the Eighth Circuit · 1973
  3. American Bronze Corp. v. CommissionerUnited States Tax Court · 1975
  4. Kern's Bakery of Virginia, Inc. v. CommissionerUnited States Tax Court · 1977
  5. Consolidated Blenders, Inc. v. United StatesDistrict Court, D. Nebraska · 1984

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