Associated Machine v. Commissioner
United States Tax Court
Corporations A (Shop) and B (J & M), California corporations, carried on separate but similar businesses in California. A was merged into B in 1960 in a statutory merger under the law of California. B, the surviving corporation, is the petitioner.
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Corporations A (Shop) and B (J & M), California corporations, carried on separate but similar businesses in California. A was merged into B in 1960 in a statutory merger under the law of California. B, the surviving corporation, is the petitioner. B, after the merger, carried on the businesses formerly carried on separately by A and B. Held, the combination of A and B into B was not a "mere change in identity, form, or place of organization" within the meaning of sec. 368(a)(1)(F), 1954 Code; therefore, a post-merger net operating loss of B could not be carried back to a premerger year of A,…
1Opinion of the Court
Associated Machine (Formerly Associated Machine Shop), a Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent
Associated Machine v. Commissioner
Docket No. 5177-65
United States Tax Court
48 T.C. 318; 1967 U.S. Tax Ct. LEXIS 93;
June 15, 1967, Filed
Decision will be entered for the respondent.
Corporations A (Shop) and B (J & M), California corporations, carried on separate but similar businesses in California. A was merged into B in 1960 in a statutory merger under the law of California. B, the surviving corporation, is the petitioner. B, after the merger, carried on the…
2Cases cited14 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
- Marr v. United StatesSupreme Court of the United States · 1925
- 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
- Cullinan v. Walker, Collector of Internal RevenueSupreme Court of the United States · 1923
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