BROWN DYNALUBE COMPANY v. C.I.R.

No. 8457.

297 F.2d 915 (1962)

BROWN DYNALUBE COMPANY, Inc., Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Fourth Circuit.

Decided January 11, 1962.


Attorney(s) appearing for the Case

William Thomas Minor, Jr., Charlotte, N. C., for petitioner.

Robert W. Kernan, Atty., Dept. of Justice, Washington, D. C. (Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson and Kenneth E. Levin, Attys., Dept. of Justice, Washington, D. C., on brief), for respondent.

Before SOPER, BRYAN and BELL, Circuit Judges.


SOPER, Circuit Judge.

This petition for review seeks the reversal of a decision of the Tax Court holding that the losses suffered by a corporation while acting as an agent for the sale of lubricating devices could not be carried over and deducted from profits earned by it in later years in the leasing of automatic packaging machines after control of the corporation had passed into different hands. The Tax Court held that the corporation was not entitled to the net...

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