Elko Realty Company v. Commissioner of Internal Revenue

The taxpayer asks us to review the decision of the Tax Court that it owed deficiencies in income tax for the years 1951,1952 and 1953. The deficiencies resulted from the disallowance by the Commissioner of losses sustained by two affiliated corporations, which losses had been set off by the taxpayer against its income in consolidated returns filed by it for the years in question. The Tax Court sustained the Commissioner’s determination that the principal purpose of the acquisition of the two corporations by the taxpayer was the avoidance of Federal income taxes, that the deduction of their…