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HERCULITE PROTECTIVE FABRICS CORP. v. COMMISSIONER

Docket No. 3587-64.

25 T.C.M. 1436 (1966)

T.C. Memo. 1966-277

Herculite Protective Fabrics Corp. v. Commissioner.

United States Tax Court.

Filed December 28, 1966.

Attorney(s) appearing for the Case

Norman E. Schlesinger and Gerald P. Seid, 11 Commerce St., Newark, N. J., for the petitioner. Donald H. Cuozzo, for the respondent.

Memorandum Findings of Fact and Opinion

MULRONEY, Judge:

Respondent determined a deficiency in petitioner's income tax for 1961 in the amount of $51,143.64. The only issue is whether petitioner's deduction in 1961 for net operating losses incurred in prior years should be disallowed because of the provisions of section 269 of the 1954 I. R. C.1 or because of the special limitations on net operating loss carryovers in section...

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