Legal Opinion
Hermes Consolidated, Inc. v. United States
United States Court of Claims
Decided March 4, 1988No. 570-83TPublishedCited by 8 opinions
1Opinion of the Court
OPINION
SMITH, Chief Judge.
This is a tax refund case for income taxes of $727,830 in principal, $311,730.59 in assessed interest, and an uncalculated amount of accrued statutory interest thereon. These amounts represent net operating loss carry-overs deducted in 1978 by plaintiff under I.R.C. § 172 (1978), but denied by the Internal Revenue Service (the Service) on the basis of I.R.C. §§ 269 and 382 (1978).
The Service disallowed plaintiffs deductions on the basis of sections 269 and 382 because the Service believed that Hermes had undergone a substantial change in its line of business and at…
2Cases cited37 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Crane v. CommissionerSupreme Court of the United States · 1947
- Metcalf & Eddy v. MitchellSupreme Court of the United States · 1926
- Burton-Sutton Oil Co. v. CommissionerSupreme Court of the United States · 1946
- Marie H. Hamm v. Commissioner of Internal Revenue, William Hamm, Jr. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1963
32 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Alumax Inc. v. CommissionerUnited States Tax Court · 1997
- Kraft, Inc. v. United StatesUnited States Court of Federal Claims · 1994
- Okerlund v. United StatesUnited States Court of Federal Claims · 2002
- Aetna Life Insurance v. United StatesUnited States Court of Claims · 1989
- Krapf v. United StatesUnited States Court of Claims · 1989
3 more not listed; retrieve them via the Exa API.