Daytona Beach Kennel Club, Inc. v. Commissioner
United States Tax Court
Petitioner acquired all the stock of Magnolia Park in 1966 in a reorganization of Magnolia Park under ch. X of the Bankruptcy Act. In 1969 Magnolia Park was merged into petitioner, and petitioner thereafter claimed net operating loss deductions based on a carryover of operating losses incurred by Magnolia Park prior to and during its bankruptcy.
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Petitioner acquired all the stock of Magnolia Park in 1966 in a reorganization of Magnolia Park under ch. X of the Bankruptcy Act. In 1969 Magnolia Park was merged into petitioner, and petitioner thereafter claimed net operating loss deductions based on a carryover of operating losses incurred by Magnolia Park prior to and during its bankruptcy. In the notice of deficiency respondent disallowed the deductions under secs. 381 and 382, I.R.C. 1954. At trial respondent stipulated that those sections did not disallow the deductions but that he was relying on sec. 269, I.R.C. 1954, and the case of…
1Opinion of the Court
Daytona Beach Kennel Club, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Daytona Beach Kennel Club, Inc. v. Commissioner
Docket No. 7798-75
United States Tax Court
69 T.C. 1015; 1978 U.S. Tax Ct. LEXIS 143;
March 30, 1978, Filed
Decision will be entered under Rule 155.
Petitioner acquired all the stock of Magnolia Park in 1966 in a reorganization of Magnolia Park under ch. X of the Bankruptcy Act. In 1969 Magnolia Park was merged into petitioner, and petitioner thereafter claimed net operating loss deductions based on a carryover of operating losses incurred by Magnolia Park prior…
2Cases cited17 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
- Bobsee Corporation v. United StatesCourt of Appeals for the Fifth Circuit · 1969
- Commodores Point Terminal Corp. v. CommissionerUnited States Tax Court · 1948
- A. C. Willingham v. United StatesCourt of Appeals for the Fifth Circuit · 1961
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