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CLARE COMPANY v. COMMISSIONER

Docket No. 3556-68.

28 T.C.M. 1348 (1969)

T.C. Memo. 1969-264

The Clare Company, a corporation, v. Commissioner.

United States Tax Court.

Filed December 9, 1969.

Attorney(s) appearing for the Case

Ralph Bohannon and Herbert G. Underwood, 10th Floor, Union Bank Bldg., Clarksburg, West Va., for the petitioner. Rodney G. Haworth, for the respondent.

Memorandum Findings of Fact and Opinion

TIETJENS, Judge:

The Commissioner determined deficiencies in income taxes for the taxable years 1960 and 1961 in the amounts of $30,969 and $15,346.25, respectively. The only issue for decision is whether section 382(a), I. R. C. 1954, precludes the deduction in 1960 and 1961 of net operating loss carryovers, resulting from losses sustained in taxable years 1956, 1957, and...

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