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