Legal Opinion
E. A. Roberts v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided July 23, 1958No. 16988PublishedCited by 11 opinions
1Opinion of the Court
RIVES, Circuit Judge.
The Tax Court decided that there are deficiencies in income tax for the taxable years 1945 and 1946 in the respective amounts of $42,967.50 and $38.391.44. Those deficiencies resulted from the Tax Court’s determination of the net operating loss sustained by the taxpayer during the year 1947 available to him as a carry-back to the years 1945 and 1946 under Section 122 of the Internal Revenue Code of 1939. The pertinent parts of that section and of the related section 23 read as follows:
“§ 23. Deductions from gross income. In computing net income there shall be allowed as…
2Cases cited11 opinions
- Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
- Edward Folker v. James W. Johnson, Individually and as a Former Collector of Internal RevenueCourt of Appeals for the Second Circuit · 1956
- Hughes v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1930
- Sic v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1949
- Pettit v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1949
6 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Whipple v. CommissionerSupreme Court of the United States · 1963
- John M. Trent and Lisa M. Trent v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1961
- King County Fire Protection District No. 16 v. Housing AuthorityWashington Supreme Court · 1994
- Lloyd U. Noland, Jr., and Jane K. Noland v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1959
- Martin v. CommissionerUnited States Tax Court · 1971
6 more not listed; retrieve them via the Exa API.