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GLEN RAVEN MILLS, INC. v. COMMISSIONER

Docket No. 4495-70.

59 T.C. 1 (1972)

GLEN RAVEN MILLS, INC., FORMERLY GLEN RAVEN COTTON MILLS, INC., SUCCESSOR BY MERGER TO ASHEVILLE HOSIERY COMPANY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 2, 1972.

Attorney(s) appearing for the Case

Joseph Warren III and Mark B. Edwards, for the petitioner.

Ocie F. Murray, Jr., for the respondent.

IRWIN, Judge:

Respondent determined deficiencies in the income taxes of Asheville Hosiery Co. of $42,275.45 and $85,504.28 for the calendar years 1964 and 1965, respectively. Petitioner has conceded that a claimed loss deduction was not allowable. Accordingly, the single issue remaining for decision is whether Asheville Hosiery Co. was prevented by either section 382 or section 2691 from deducting prior period net operating losses...

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