FRANK SPINGOLO WAREHOUSE CO., INC. v. COMMISSIONER

Docket No. 76980.

37 T.C. 1 (1961)

FRANK SPINGOLO WAREHOUSE COMPANY, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 6, 1961.


Attorney(s) appearing for the Case

Robert E. Tout, Esq., for the petitioner.

James Booher, Esq., for the respondent.


The Commissioner determined deficiencies in petitioner's income tax for the calendar year 1954 in the amount of $17,413.10 and for the taxable period January 1 to September 30, 1955, in the amount of $2,342.48.

After certain concessions by the parties, the only issue remaining is the deductibility of the $28,561.12 net operating loss deduction which petitioner claimed on its income tax return for 1954.

FINDINGS OF FACT.

Some of the facts were stipulated...

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