Libson Shops, Inc. v. Koehler, 353 U.S. 382 (1957)

Libson Shops, Inc. v. Koehler


No. 64


Argued January 15, 1957
Decided May 27, 1957
353 U.S. 382

CERTIORARI TO THE UNITED STATES COURT OF APPEALS
FOR THE EIGHTH CIRCUIT

Syllabus

Under §§ 23(s) and 122 of the Internal Revenue Code of 1939, as amended, a corporation resulting from a merger of 17 separately incorporated businesses which had filed separate income tax returns may not carry over and deduct the pre-merger net operating losses of three of its constituent corporations from the post-merger income attributable to the other businesses. Pp. 382-390.

229 F.2d 220 affirmed.