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SEASIDE VILLAGE, INC. v. DIRECTOR OF REVENUE

429 A.2d 980 (1981)

SEASIDE VILLAGE, INC., a corporation of the State of Delaware, Petitioner, Appellant, v. DIRECTOR OF REVENUE, Respondent, Appellee.

Supreme Court of Delaware.

Decided April 22, 1981.

Attorney(s) appearing for the Case

Benton C. Tolley, Jr. (argued), of Tunnell & Raysor, Georgetown, for petitioner, appellant.

John P. Fedele (argued), Deputy Atty. Gen., Wilmington, for respondent, appellee.

Before HERRMANN, C. J., DUFFY and QUILLEN, JJ.

DUFFY, Justice:

In this tax case, Seaside Village, Inc. (Seaside) appeals from a judgment of the Superior Court approving a denial of the State Director of Revenue of a request under the provisions of 30 Del.C. §§ 1908 and 1911 for two corporate tax refunds. We affirm in part, and reverse in part.

I

The facts are not in dispute.

Seaside sustained corporate net operating losses in fiscal years 1974 and 1975. Seeking to carry...

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