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AMERICAN FINANCIAL CORP. v. COMMISSIONER

Docket No. 11559-77.

72 T.C. 506 (1979)

AMERICAN FINANCIAL CORPORATION (SUCCESSOR IN INTEREST TO NATIONAL GENERAL CORPORATION, THE SUCCESSOR IN INTEREST TO GREAT AMERICAN HOLDING COMPANY) AND SUBSIDIARIES, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 14, 1979.

Attorney(s) appearing for the Case

Bart A. Brown, Jr., for the petitioners.

Karl D. Zufelt, for the respondent.

OPINION

DAWSON, Judge:

Respondent determined a deficiency in petitioner's consolidated Federal income tax for 1968 in the amount of $210,929. In its petition, however, petitioner alleged an overpayment for 1968 in the amount of $527,969. By an amendment to his answer the respondent alleged, as an offset to the overpayment claimed in the petition, that petitioner's net operating loss carryover deduction in...

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