Chartier Real Estate Co. v. Commissioner
United States Tax Court
1. T corporation, for its taxable year ending June 30, 1962, had capital gain income of $ 83,787.64 and ordinary income of $ 1,115.57. It had an unused net operating loss of $ 11,458.21 from the next 2 taxable years which could be carried back to the taxable year ending June 30, 1962. Held, in computing tax under the "alternative" method provided in sec. 1201(a), I.R.C. 1954, no part of the net operating loss may be applied against the capital gain.
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1. T corporation, for its taxable year ending June 30, 1962, had capital gain income of $ 83,787.64 and ordinary income of $ 1,115.57. It had an unused net operating loss of $ 11,458.21 from the next 2 taxable years which could be carried back to the taxable year ending June 30, 1962. Held, in computing tax under the "alternative" method provided in sec. 1201(a), I.R.C. 1954, no part of the net operating loss may be applied against the capital gain. Walter M. Weil, 23 T.C. 424, affirmed 229 F. 2d 593 (C.A. 6) followed. 2. Held, that part of the net operating loss not absorbed in the…
1Opinion of the Court
Chartier Real Estate Company, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Chartier Real Estate Co. v. Commissioner
Docket Nos. 838-66, 2116-67
United States Tax Court
52 T.C. 346; 1969 U.S. Tax Ct. LEXIS 121;
May 29, 1969, Filed
Decisions will be entered under Rule 50.
1. T corporation, for its taxable year ending June 30, 1962, had capital gain income of $ 83,787.64 and ordinary income of $ 1,115.57. It had an unused net operating loss of $ 11,458.21 from the next 2 taxable years which could be carried back to the taxable year ending June 30, 1962. Held, in computing tax under…
2Cases cited12 opinions
- Tyler v. United StatesSupreme Court of the United States · 1930
- Irwin v. GavitSupreme Court of the United States · 1925
- Walter M. Weil and Adele D. Weil v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1956
- Chartier Real Estate Co. v. CommissionerUnited States Tax Court · 1969
- Weil v. CommissionerUnited States Tax Court · 1954
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