Libson Shops, Inc., v. Koehler, District Director of Internal Revenue

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• wherein the taxpayer unsuccessfully attempted to set off premerger losses of one business against postmerger income of another
• wherein the taxpayer unsuccessfully attempted to set off premerger losses of one business against postmerger income of another
• loss carryover not permitted after merger unless the income against which the deduction is claimed was produced by substantially the same business which incurred the loss
• net operating loss carryovers and carrybacks “were designed to permit a taxpayer to set off its lean years against its lush years, and to strike something like an average taxable income computed over a period longer than one year” (footnote omitted)
• net operating loss carryovers and carrybacks “were designed to permit a taxpayer to set off its lean years against its lush years, and to strike something like an aver- age taxable income computed over a period longer than one year” (footnote omitted)
• decided since the briefs herein were submitted

Source: CourtListener parenthetical corpus (CC0).