Libson Shops, Inc. v. Koehler
United States Supreme Court
353 U.S. 382 (1957)
- Written by Eric Miller, JD
Facts
Libson Shops, Inc., a women’s-apparel retailer, was incorporated around the same time that 16 other sales corporations were separately incorporated by the same interests. The 17 businesses initially filed separate income-tax returns. Three of the businesses showed net operating losses, totaling $22,432.76. Then the 16 enterprises other than Libson Shops were merged into Libson Shops, which conducted the entire business as a single entity. Libson Shops deducted the $22,432.76 as a carryover from the previous tax year. The Commissioner of Internal Revenue disallowed the deduction and assessed a tax deficiency. Libson Shops brought suit for a refund. The district court dismissed the complaint. The court of appeals affirmed. Libson Shops appealed. The United States Supreme Court granted certiorari.
Rule of Law
Issue
Holding and Reasoning (Burton, J.)
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