JULIUS GARFINCKEL & CO. v. COMMISSIONER

Docket No. 94340.

40 T.C. 870 (1963)

JULIUS GARFINCKEL & CO., INCORPORATED (SUCCESSOR TO BROOKS BROTHERS, INC., FORMERLY THE A. DE PINNA COMPANY), PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 20, 1963.


Attorney(s) appearing for the Case

Wallace S. Jones and Richard R. Dailey, for the petitioner.

Joseph Wilkes, for the respondent.


MULRONEY, Judge:

The respondent determined a deficiency in petitioner's income tax for the taxable year ended July 31, 1953, in the amount of $307,308.13. The issue is whether certain premerger losses can be carried over and offset against certain postmerger income.

FINDINGS OF FACT

Some of the facts are stipulated and they are found accordingly.

Petitioner is a Virginia corporation with its principal place of business in Washington...

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