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SWISS COLONY, INC. v. C. I. R.

No. 17837.

428 F.2d 49 (1970)

The SWISS COLONY, INC., Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Seventh Circuit.

June 3, 1970.

Attorney(s) appearing for the Case

John L. Palmer, George B. Sletteland, Anthony W. Asmuth III, Milwaukee, Wis., for petitioner; Whyte, Hirschboeck, Minahan, Harding & Harland, Milwaukee, Wis., of counsel.

Johnnie M. Walters, Tax Division, Lee A. Jackson, Gilbert E. Andrews, Gordon S. Gilman, Attys., U.S. Dept. of Justice, Washington, D. C., for respondent.

Before SWYGERT, Chief Judge, FAIRCHILD, Circuit Judge and CAMPBELL, District Judge.

CAMPBELL, District Judge*.

This appeal is taken by taxpayer, The Swiss Colony, Inc., ("Taxpayer") from a decision of the Tax Court which sustained deficiency determinations for the years ended August 31, 1962, 1963 and 1964 in the respective amounts of $6,399.48, $18,609.82 and $43,110.82. The issue before the Tax Court, and here on appeal, relates to Taxpayer's right to certain net operating loss deductions in 1963 and 1964 based on net...

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