Midland Management Co. v. Commissioner
United States Tax Court
Held, petitioner, as the common parent corporation, and its several affiliates are not entitled to deduct a consolidated net operating loss carryback where six of the affiliated corporations to which the losses are attributable were not members of the affiliated group and not in existence during the year to which the losses are sought to be carried.
1Opinion of the Court
Midland Management Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
Midland Management Co. v. Commissioner
Docket No. 86342
United States Tax Court
38 T.C. 211; 1962 U.S. Tax Ct. LEXIS 139;
May 7, 1962, Filed
Decision will be entered for the respondent.
Held, petitioner, as the common parent corporation, and its several affiliates are not entitled to deduct a consolidated net operating loss carryback where six of the affiliated corporations to which the losses are attributable were not members of the affiliated group and not in existence during the year to which the losses are…
2Cases cited10 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Seaboard Commercial Corp. v. CommissionerUnited States Tax Court · 1957
- Trinco Industries, Inc. v. CommissionerUnited States Tax Court · 1954
- Swift & Co. v. United StatesUnited States Court of Claims · 1930
- Robert L. Phinney and United States of America v. Houston Oil Field Material Company, Inc., and Its SubsidiariesCourt of Appeals for the Fifth Circuit · 1958
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