J. G. Dudley Co. v. Commissioner
United States Tax Court
Held, petitioner may not claim carryovers, as deductions, of net operating losses from prior years to the taxable years. Libson Shops, Inc. v. Koehler, 353 U.S. 382, and Thomas E. Snyder Sons Co., 34 T. C. 400, followed.
1Opinion of the Court
Tietjens, Judge:
The Commissioner determined deficiencies in income tax of $3,604.47 and $5,907.96 for the taxable years 1954 and 1955, respectively.
The only question for decision is whether the petitioner may properly claim carryovers, as deductions, of net operating losses from prior years to the taxable years.
FINDINGS OF FACT.
Some of the facts are stipulated, are so found, and the stipulated facts are included herein by this reference.
The petitioner was formerly Headen Hosiery Mills, Incorporated (herein sometimes called Headen Hosiery). Headen Hosiery was incorporated under the North…
2Cases cited9 opinions
- Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
- Mill Ridge Coal Company v. George D. Patterson, District Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1959
- Thomas E. Snyder Sons Co. v. CommissionerUnited States Tax Court · 1960
- Urban Redevelopment Corp. v. CommissionerUnited States Tax Court · 1960
- W A G E, Inc. v. CommissionerUnited States Tax Court · 1952
4 more not listed; retrieve them via the Exa API.
3Cited by28 opinions
- Ach v. CommissionerUnited States Tax Court · 1964
- Humacid Co. v. CommissionerUnited States Tax Court · 1964
- H. F. Ramsey Co. v. CommissionerUnited States Tax Court · 1965
- Huyler's (Corp.) v. CommissionerUnited States Tax Court · 1962
- Frederick Steel Co. v. CommissionerUnited States Tax Court · 1964
23 more not listed; retrieve them via the Exa API.