Legal Opinion
The Zanesville Investment Company v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
Decided August 12, 1964No. 15282_1PublishedCited by 21 opinions
1Opinion of the Court
LEVIN, District Judge.
The question presented for decision is whether ¿Section 269 1 of the Internal Revenue Code of 1954 or some judicially enunciated principle of law preveñts~TiEé offseftíñg"~iñ~ a consolidated return of cash operating losses and losses realized on the sale of physical assets sustained after affiliation by one corporate member of an affiliated group with the post-affiliation profits of another corporate member thereof, where it could be anticipated that such operating losses would be incurred.
The cases principally relied on by the Government 2 are not apposite, as they…
2Cases cited17 opinions
- Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
- American Pipe & Steel Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 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. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1961
- James Realty Company, a Corporation v. United StatesCourt of Appeals for the Eighth Circuit · 1960
12 more not listed; retrieve them via the Exa API.
3Cited by21 opinions
- Victor Borge, Sanna Borge, and Danica Enterprises, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1968
- Wolter Construction Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1980
- D'Arcy-MacManus & Masius, Inc. v. CommissionerUnited States Tax Court · 1975
- Supreme Investment Corporation v. United StatesCourt of Appeals for the Fifth Circuit · 1972
- Canaveral Int'l Corp. v. CommissionerUnited States Tax Court · 1974
16 more not listed; retrieve them via the Exa API.