Electronic Sensing Products, Inc. v. Commissioner
United States Tax Court
Petitioner organized a wholly owned subsidiary (H) on Oct. 6, 1972, and another wholly owned subsidiary (D) on Feb. 15, 1973. Petitioner and H filed separate income tax returns for their respective taxable years ended Oct. 31, 1972 (Nov. 1, 1971, to Oct. 31, 1972, for petitioner and Oct. 6, 1972, to Oct. 31, 1972, for H). Petitioner and H and D filed a consolidated return for the taxable year ended Oct. 31, 1973, reflecting a net operating loss attributable to all three…
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Petitioner organized a wholly owned subsidiary (H) on Oct. 6, 1972, and another wholly owned subsidiary (D) on Feb. 15, 1973. Petitioner and H filed separate income tax returns for their respective taxable years ended Oct. 31, 1972 (Nov. 1, 1971, to Oct. 31, 1972, for petitioner and Oct. 6, 1972, to Oct. 31, 1972, for H). Petitioner and H and D filed a consolidated return for the taxable year ended Oct. 31, 1973, reflecting a net operating loss attributable to all three corporations. Because of losses incurred by petitioner for its taxable year ended Oct. 31, 1968, through its taxable year…
1Opinion of the Court
OPINION
Goffe, Judge:
The Commissioner determined a deficiency of $429,327 in the Federal corporation income tax of petitioner for the taxable year ended October 31, 1972. This matter is before this Court on a joint motion for partial summary judgment pursuant to Rule 121 of the Court’s Rules of Practice and Procedure. The motion raises one issue for decision, whether the net operating loss of Homecraft Products, Inc. (a wholly owned subsidiary of petitioner, referred to hereafter as Homecraft), for the taxable year ended October 31, 1973, in which it filed a consolidated return with…
2Cases cited7 opinions
- Interstate Transit Lines v. CommissionerSupreme Court of the United States · 1943
- National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
- Woolford Realty Co. v. RoseSupreme Court of the United States · 1932
- 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
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3Cited by17 opinions
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- Amorient, Inc. v. CommissionerUnited States Tax Court · 1994
- Jim Burch & Associates, Inc. v. CommissionerUnited States Tax Court · 1981
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