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COMMONWEALTH CONTAINER CORP. v. COMMISSIONER

Docket No. 2427-65.

48 T.C. 483 (1967)

COMMONWEALTH CONTAINER CORP., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 28, 1967.

Attorney(s) appearing for the Case

Norman E. Schlesinger, for the petitioner.

Albert Squire, for the respondent.

DRENNEN, Judge:

Respondent determined deficiencies in petitioner's income taxes for the calendar years 1961 and 1962 in the amounts of $66,597.10 and $69,310.14, respectively. The only issue is what part of the net operating loss carryover of Tri-City Container Corp. (hereinafter referred to as Tri-City), which merged into petitioner on or about June 21, 1961,1 may be included in petitioner...

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