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FAIRFIELD COMMUNITIES LAND COMPANY v. COMMISSIONER

Docket No. 6164-78.

47 T.C.M. 1194 (1984)

T.C. Memo. 1984-100

Fairfield Communities Land Company and Affiliated Subsidiaries v. Commissioner.

United States Tax Court.

Filed March 1, 1984.

Attorney(s) appearing for the Case

Alston Jennings, Terry L. Mathews, 2200 Worthen Bank Bldg., Little Rock, Ark., and Elizabeth Blaich, for the petitioner. Deborah A. Butler, for the respondent.

Memorandum Findings of Fact and Opinion

DRENNEN, Judge:

Respondent determined deficiencies in petitioner's consolidated income taxes for the fiscal years ending February 28, 1974 and 1975, and February 29, 1976 in the amounts of $458,878, $218,846, and $3,297, respectively. The sole issue for decision is whether petitioners are precluded by section 269, I.R.C. 1954,1 from deducting the net operating losses of Oceans General,...

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