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A. R. RUPPERT PLUMBING & HEATING CO. v. COMMISSIONER

Docket No. 84497.

39 T.C. 284 (1962)

A. R. RUPPERT PLUMBING & HEATING CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 31, 1962.

Attorney(s) appearing for the Case

H. O. Hart (an officer), for the petitioner.

Eugene F. Reardon, Esq., and Edward M. Fox, Esq., for the respondent.

OPINION.

ARUNDELL, Judge:

Respondent determined a deficiency in income tax for the fiscal year ending September 30, 1954, in the amount of $16,291.34. Instead of a deficiency petitioner claims an overpayment in the amount of $4,544.83.

The only issue is whether income earned by a subsidiary corporation which filed a consolidated income tax return with its parent corporation (petitioner herein) can be offset by a net operating loss deduction...

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