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CONTADINA FOODS, INC. v. COMMISSIONER

Docket No. 89826.

21 T.C.M. 602 (1962)

T.C. Memo. 1962-110

Contadina Foods, Inc. (formerly Hershel California Food Products Company) successor to Matmor Canning Company, Inc. v. Commissioner.

United States Tax Court.

Filed May 3, 1962.

Attorney(s) appearing for the Case

Walter G. Schwartz, Esq., for the petitioner. Joseph D. Holmes, Jr., Esq., for the respondent.

Memorandum Findings of Fact and Opinion

MURDOCK, Judge:

The Commissioner determined a deficiency in income tax of $16,857.16 for the fiscal year ended November 30, 1950, and one of $49,506.06 for the year ended November 30, 1951. The only issue for decision is whether the Commissioner erred in disallowing for 1951 a part of a claimed net operating loss carry-back from 1952. Decision of this issue depends entirely upon the value of "96/6" tomato paste to...

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