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ROYAL OAK APARTMENTS, INC. v. COMMISSIONER

Docket No. 3282-62.

43 T.C. 243 (1964)

ROYAL OAK APARTMENTS, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 30, 1964.

Attorney(s) appearing for the Case

Rucker Todd, for the petitioner.

Sanford S. Neuman, for the respondent.

OPINION

FORRESTER, Judge:

The year at issue before us is petitioner's fiscal year ending March 31, 1958. The sole remaining issue before us involves a claimed carryback net operating loss deduction to such year from petitioner's fiscal year ending March 31, 1961. The claimed loss item during fiscal 1961 is a corporation excise tax in the amount of $17,653.87 which was paid to the State of Tennessee during such year, but respondent contends it is not...

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