Legal Opinion

Nibur Bldg. Corp. v. Commissioner

United States Tax Court

Decided April 23, 1970No. Docket No. 115-68Published

Held, for taxable years commencing prior to Jan. 1, 1966, the portion of a consolidated net operating loss attributable to a subsidiary cannot be carried back to offset the income of the parent corporation in a separate return year prior to incorporation of the subsidiary.

1Opinion of the Court

Nibur Building Corporation, and its Wholly Owned Subsidiary, Ralston Steel Corporation, Petitioners v. Commissioner of Internal Revenue, Respondent

Nibur Bldg. Corp. v. Commissioner

Docket No. 115-68

United States Tax Court

54 T.C. 835; 1970 U.S. Tax Ct. LEXIS 156;

April 23, 1970, Filed

Decision will be entered for the respondent.

Held, for taxable years commencing prior to Jan. 1, 1966, the portion of a consolidated net operating loss attributable to a subsidiary cannot be carried back to offset the income of the parent corporation in a separate return year prior to incorporation of the subsidiary.

M…

2Cases cited4 opinions

  1. Trinco Industries, Inc. v. CommissionerUnited States Tax Court · 1954
  2. American Trans-Ocean Navigation Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1956
  3. A. R. Ruppert Plumbing & Heating Co. v. CommissionerUnited States Tax Court · 1962
  4. Nibur Bldg. Corp. v. CommissionerUnited States Tax Court · 1970

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