South Texas Rice Warehouse Co. v. Commissioner
United States Tax Court
For a number of years prior to June 30, 1957, four families had owned in equal proportions two corporations, one engaged in the business of supplying water for irrigation of ricelands and leasing farmlands to a partnership consisting of the same persons as the corporate stockholders, and the other engaged in operating a warehouse for cleaning and storing rice.
Read the full summary
For a number of years prior to June 30, 1957, four families had owned in equal proportions two corporations, one engaged in the business of supplying water for irrigation of ricelands and leasing farmlands to a partnership consisting of the same persons as the corporate stockholders, and the other engaged in operating a warehouse for cleaning and storing rice. In June 1957 the corporation engaged in the warehousing business leased all its properties to a newly formed partnership for a rental of $ 48,000 a year. The new partnership was owned by the same four families in equal proportions but…
1Opinion of the Court
Scott, Judge:
Eespondent determined deficiencies in the income tax liability of petitioner South Texas Eice Warehouse Co. for the years and in the amounts as follows:
Year ended,
June 30— Deficiency
1955_ $8, 590. 87
1956_ 17,956.96
1957_ 6,442.44
1958_ 32, 903.25
1959_ 26, 711.24
1960_ 34,455. 51
Total_ 127, 060. 27
The deficiencies determined for the taxable years ended June 30,1955, 1956, and 1957, resulted from the disallowance of net operating losses, previously allowed as carrybacks from the taxable years ended June 30, 1958,1959, and 1960.
Eespondent determined deficiencies in the income taxes of…
2Cases cited20 opinions
- Higgins v. SmithSupreme Court of the United States · 1940
- Grenada Industries, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1953
- Sun Properties, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1955
- United States v. General Geophysical CompanyCourt of Appeals for the Fifth Circuit · 1961
- James Armour, Inc. v. CommissionerUnited States Tax Court · 1964
15 more not listed; retrieve them via the Exa API.
3Cited by90 opinions
- Parker v. CommissionerUnited States Tax Court · 1986
- 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
- Cal-Maine Foods, Inc. v. CommissionerUnited States Tax Court · 1989
- Brittingham v. CommissionerUnited States Tax Court · 1976
- South Texas Rice Warehouse Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1966
85 more not listed; retrieve them via the Exa API.