Legal Opinion

Frederick Steel Co. v. Commissioner of Internal Revenue

Court of Appeals for the Sixth Circuit

Decided April 28, 1967No. 16243PublishedCited by 30 opinions

1Opinion of the Court

McALLISTER, Senior Circuit Judge.

Under Internal Revenue statutes, the question whether losses incurred in prior years by a corporation may be used as carry-overs against income realized from an entirely different enterprise that was later transferred to the corporation, has, in the past, led to confusing and contradictory decisions by the Commissioner of Internal Revenue, and by the courts.

Congress, in its effort to remedy this situation, sought, in 1954, a new fully integrated revenue code. Both House and Senate Committees having the legislation for consideration reported, at that time, that…

2Cases cited6 opinions

  1. Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
  2. Black Motor Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1942
  3. Maxwell Hardware Company, a Corporation, on Review v. Commissioner of Internal Revenue, on ReviewCourt of Appeals for the Ninth Circuit · 1965
  4. Frederick Steel Co. v. CommissionerUnited States Tax Court · 1964
  5. Euclid-Tennessee, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1965

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

3Cited by30 opinions

  1. Taft Broadcasting Company v. United StatesCourt of Appeals for the Sixth Circuit · 1991
  2. Yoc Heating Corp. v. CommissionerUnited States Tax Court · 1973
  3. Byron Roberts v. John Berry, Jr.Court of Appeals for the Sixth Circuit · 1976
  4. Fehrs Finance Company, Cross-Appellee v. Commissioner of Internal Revenue, Cross-AppellantCourt of Appeals for the Eighth Circuit · 1973
  5. United States v. Adkins-Phelps, IncorporatedCourt of Appeals for the Eighth Circuit · 1968

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

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