AMERICAN AUTOMOBILE ASSOCIATION v. COMMISSIONER

Docket No. 15912.

19 T.C. 1146 (1953)

THE AMERICAN AUTOMOBILE ASSOCIATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated March 26, 1953.


Attorney(s) appearing for the Case

Charles C. Collins, Esq., and Joseph K. Moyer, Esq., for the petitioner.

James C. Maddox, Esq., for the respondent.


The Commissioner has determined deficiencies in the petitioner's income taxes for the calendar years 1943, 1944, and 1945 in the amounts of $45,687.01, $48,120.07, and $9,363.83, respectively.

The Commissioner, in his notice of deficiency, did not allow any net operating loss carry-back for the years 1944 and 1945. By a stipulation filed in this proceeding, the parties agree that the petitioner had a net operating loss for the year 1946 of $91,266.60, and a net operating...

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