HUDDLE, INC. v. COMMISSIONER

Docket No. 72071.

20 T.C.M. 745 (1961)

T.C. Memo. 1961-150

The Huddle, Inc. v. Commissioner.

United States Tax Court.

Filed May 25, 1961.


Attorney(s) appearing for the Case

Elliott Goldstein, Esq., Citizens & Southern National Bank Bldg., Atlanta, Ga., and William J. Linkous, Esq., for the petitioner. James E. Johnson, Jr., Esq., for the respondent.


Memorandum Findings of Fact and Opinion

DRENNEN, Judge:

Respondent determined deficiencies in petitioner's income tax for the fiscal years ending February 28, 1954 and 1955, in the amounts of $4,990.79 and $4,738.81, respectively.

The only question for decision is whether petitioner is entitled to carry over and deduct from income net operating losses sustained by it prior to October 31, 1952, when the ownership of all of petitioner's stock and the...

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