John M. Wiseman v. United States

This is a suit for a tax refund. In the tax year in question plaintiff taxpayer was the sole owner of two brother-sister corporations — Industrial Realty Co., Inc. and Southern Comfort Realty Company. Industrial was a successful operation — yielding substantial profits. Southern had been losing money for several years and understandably plaintiff was anxious to liquidate it. Late in March 1961, upon the recommendation of plaintiff’s accountant, a plan for Southern’s liquidation was put into effect. The primary objective of this plan was to enable Industrial to set off Southern’s losses…