Candy Bros. Mfg. Co., Inc. v. Commissioner of Internal Revenue

GARDNER, Chief Judge.

This is a petition to review a decision of the Tax Court which affirmed a decision of the Commissioner of Internal Revenue holding that in computing net income as an element of corporation surtax net income for the years 1942 and 1943 no deductions should be allowed for net operating losses for the years 1940 and 1941.

Petitioner is a Missouri corporation and during the period here involved was engaged in manufacturing and selling cough drops, candy fruit drops and other hard candies. Since December 17, 19'40, it has been a wholly owned subsidiary of Universal Match…