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MIDLAND MANAGEMENT CO. v. COMMISSIONER

Docket No. 86342.

38 T.C. 211 (1962)

MIDLAND MANAGEMENT COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 7, 1962.

Attorney(s) appearing for the Case

Murray Steinberg, Esq., for the petitioner.

James H. Martin, Esq., for the respondent.

WITHEY, Judge:

Respondent has determined a deficiency in the income tax of petitioner for its taxable year ended September 30, 1955, in the amount of $12,590.80.

The issue presented is whether the respondent has erred in disallowing the loss carryback of an affiliated group of corporations from the taxable year ended September 30, 1957, to the taxable year ended September 30, 1955, when certain corporations which sustained the losses in 1957 were not...

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