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BRITISH MOTOR CAR DISTRIBUTORS, LTD. v. COMMISSIONER

Docket No. 63520.

31 T.C. 437 (1958)

BRITISH MOTOR CAR DISTRIBUTORS, LTD., A CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 26, 1958.

Attorney(s) appearing for the Case

Frederic T. Leo, Esq., and Clyde C. Sherwood, Esq., for the petitioner.

Charles W. Nyquist, Esq., for the respondent.

OPINION.

TIETJENS, Judge:

The Commissioner determined deficiencies in income and excess profits tax of $137,057.99 and $31,846.12 for the fiscal years ended October 31, 1952, and October 31, 1953, respectively.

The only issue for decision is whether petitioner is entitled to carry over against its income from the sale of automobiles and parts in the taxable years, net operating losses sustained by Empire Home Equipment Co., Inc., in its fiscal...

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