Chartier Real Estate Company, Inc. v. Commissioner of Internal Revenue, (Three Cases)
This text of 428 F.2d 474 (Chartier Real Estate Company, Inc. v. Commissioner of Internal Revenue, (Three Cases)) is published on Counsel Stack Legal Research, covering Court of Appeals for the First Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.
Opinion
The decisions of the Tax Court are affirmed, essentially on its opinion. 52 T.C. 346 (1969). So far as the year 1962 is concerned the result of what seems the prima facie meaning of the statute does not even appear unreasonable. It does not seem inappropriate to place a floor at the alternate tax, leaving unused losses to their carryover utility, if any. Correspondingly, as to 1965, we do not fault the Tax Court’s conclusion that in section 172(b) (2), “ ‘taxable income’ means that taxable income to which the loss is actually applied in computing actual tax liability.” No useful purpose would be served by further elaboration on these unimportant and seldom occurring questions.
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Cite This Page — Counsel Stack
428 F.2d 474, 25 A.F.T.R.2d (RIA) 1296, 1970 U.S. App. LEXIS 8994, Counsel Stack Legal Research, https://law.counselstack.com/opinion/chartier-real-estate-company-inc-v-commissioner-of-internal-revenue-ca1-1970.