Legal Opinion
National Tea Co. v. Commissioner
Court of Appeals for the Seventh Circuit
Decided June 16, 1986No. 85-1484PublishedCited by 2 opinions
1Opinion of the Court
CUMMINGS, Chief Judge.
This case comes to us on appeal from the United States Tax Court, 83 T.C. 8, which granted summary judgment in favor of the respondent Commissioner of Internal Revenue (“Commissioner”) against the petitioner National Tea Co. and Consolidated Subsidiaries (“National Tea”). The issue raised is whether an acquiring corporation, which seeks to carryback net operating losses it incurred subsequent to a reorganization (stipulated by the parties to be a reorganization as defined by Section 368(a)(1)(F) of the Internal Revenue Code, i.e., an “F” reorganization) to income earned…
2Cases cited19 opinions
- Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
- J. E. Davant and Kathryn Davant v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. J. E. Davant and Kathryn DavantCourt of Appeals for the Fifth Circuit · 1966
- Estate of Bernard H. Stauffer, Bonnie H. Stauffer v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1968
- Maxwell Hardware Company, a Corporation, on Review v. Commissioner of Internal Revenue, on ReviewCourt of Appeals for the Ninth Circuit · 1965
- Associated MacHine (Formerly Associated MacHine Shop), a Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1968
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3Cited by2 opinions
- United States Ex Rel. Internal Revenue Service v. Quaid (In Re Luster)District Court, N.D. Illinois · 1992
- National Tea Co. v. Commissioner Of Internal RevenueCourt of Appeals for the Seventh Circuit · 1986