FRANK IX & SONS VIRGINIA CORPORATION v. C. I. R.

No. 16131.

375 F.2d 867 (1967)

FRANK IX & SONS VIRGINIA CORPORATION, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Third Circuit.

Decided April 12, 1967.

Rehearing Denied May 1, 1967.


Attorney(s) appearing for the Case

Benjamin Nadel, Norman Nadel, New York City, for petitioner.

Gilbert E. Andrews, Atty., Dept. of Justice, Tax Division, Mitchell Rogovin, Asst. Atty. Gen., Lee A. Jackson, Anthony Zell Roisman, Attys., Dept. of Justice, Washington, D. C., for respondent.

Before McLAUGHLIN, SMITH, and FREEDMAN, Circuit Judges.


OPINION OF THE COURT

FREEDMAN, Circuit Judge:

Petitioner attacks the Tax Court's disallowance of net operating loss carryover deductions on losses which it incurred prior to a reorganization.

The Ix family, through a number of corporations, was engaged in the manufacture and sale of woven synthetic fibers. Separate corporations operated separate mills which manufactured the same types and styles of cloth...

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