Legal Opinion
Springfield Street Railway Company v. The United States
United States Court of Claims
Decided January 11, 1963No. 26-62PublishedCited by 24 opinions
1Opinion of the Court
LARAMORE, Judge.
The plaintiff in this action seeks an income tax refund for the year 1954. Its claim is premised upon a 1955 net operating loss being carried back against 1954 income. The case arises upon the defendant’s motion to dismiss.
The ultimate question raised before this court concerns the amount of 1955 carryback loss to be allocated between 1953 and 1954 income. The carryback loss must first be applied against 1953 income. 1 If any loss remains, it may then be applied against 1954 income. The plaintiff reported a taxable income in 1953 sufficient to absorb all of the car-ryback…
2Cases cited17 opinions
- Lewis v. ReynoldsSupreme Court of the United States · 1932
- Commissioner v. DisstonSupreme Court of the United States · 1945
- Phoenix Coal Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1956
- Leuthesser v. CommissionerUnited States Tax Court · 1952
- Budd Company v. United StatesCourt of Appeals for the Third Circuit · 1957
12 more not listed; retrieve them via the Exa API.
3Cited by24 opinions
- Mennuto v. CommissionerUnited States Tax Court · 1971
- Bernard M. Barenholtz v. The United StatesCourt of Appeals for the Federal Circuit · 1986
- Grapevine Imports, Ltd. v. United StatesUnited States Court of Federal Claims · 2007
- Maxcy v. CommissionerUnited States Tax Court · 1973
- Midland-Ross Corporation, Transferee of Surface Combustion Corporation v. United StatesCourt of Appeals for the Sixth Circuit · 1973
19 more not listed; retrieve them via the Exa API.