Legal Opinion

Hart Metal Products Corp. v. Commissioner

United States Tax Court

Decided August 13, 1969No. Docket No. 4777-66UnpublishedCited by 5 opinions

Held, that the petitioner has failed to prove that the respondent erred in determining that the principal purpose for the acquisition of control of petitioner on February 29, 1960, was the evasion or avoidance of Federal income tax by securing to the acquirer the benefit of a deduction of petitioner's claimed net operating losses and in therefore disallowing the deduction of such claimed losses under section 269 of the Internal Revenue Code of 1954. Held further, that the…

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Held, that the petitioner has failed to prove that the respondent erred in determining that the principal purpose for the acquisition of control of petitioner on February 29, 1960, was the evasion or avoidance of Federal income tax by securing to the acquirer the benefit of a deduction of petitioner's claimed net operating losses and in therefore disallowing the deduction of such claimed losses under section 269 of the Internal Revenue Code of 1954. Held further, that the petitioner has failed to prove that it is entitled to a claimed long-term capital loss for the taxable year ended…

1Opinion of the Court

Hart Metal Products Corporation v. Commissioner.

Hart Metal Products Corp. v. Commissioner

Docket No. 4777-66.

United States Tax Court

T.C. Memo 1969-164; 1969 Tax Ct. Memo LEXIS 129; 28 T.C.M. (CCH) 810; T.C.M. (RIA) 69164;

August 13, 1969. Filed

Held, that the petitioner has failed to prove that the respondent erred in determining that the principal purpose for the acquisition of control of petitioner on February 29, 1960, was the evasion or avoidance of Federal income tax by securing to the acquirer the benefit of a deduction of petitioner's claimed net operating losses and in therefore…

2Cases cited6 opinions

  1. Burnet v. HoustonSupreme Court of the United States · 1931
  2. Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
  3. United States v. International Building Co.Supreme Court of the United States · 1953
  4. Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
  5. Swiss Colony, Inc. v. CommissionerUnited States Tax Court · 1969

1 more not listed; retrieve them via the Exa API.

3Cited by5 opinions

  1. Metro Leasing & Dev. Corp. v. Comm'rUnited States Tax Court · 2002
  2. Kaldi v. Comm'rUnited States Tax Court · 2007
  3. Metro Leasing & Dev. Corp. v. Comm'rUnited States Tax Court · 2002
  4. Metro Leasing and Development Corporation, East Bay Chevrolet Company, a Corporation v. CommissionerUnited States Tax Court · 2002
  5. Thu Cuc Thi Huynh v. Comm'rUnited States Tax Court · 2002

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