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WOLTER CONST. CO., INC. v. C. I. R.

No. 77-1677.

634 F.2d 1029 (1980)

WOLTER CONSTRUCTION COMPANY, INC., Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided November 17, 1980.

Attorney(s) appearing for the Case

Charles F. Hartsock, James W. Halloran, James J. Cunningham, Cincinnati, Ohio, for petitioner-appellant.

M. Carr Ferguson, Asst. Atty. Gen., Jonathan S. Cohen, John G. Manning, Tax Div., U. S. Dept. of Justice, Washington, D. C., Gilbert E. Andrews, Stuart E. Seigel, Chief Counsel, Internal Revenue Service, Washington, D. C., for respondent-appellee.

Before CELEBREZZE, ENGEL and BOYCE F. MARTIN, Jr., Circuit Judges.

CELEBREZZE, Circuit Judge.

The question in this case is whether deductions claimed on a consolidated income tax return filed by a parent corporation and its controlled subsidiary corporation, with respect to net operating losses sustained by the subsidiary in years prior to its affiliation with the parent, are allowable as net operating loss carryovers when the subsidiary had no post-consolidation income for the tax years in question.

I.

Wolter Construction...

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