UNITED STATES SUPREME COURT DECISIONS ON-LINE

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. 353 U. S. 382-390.

229 F.2d 220 affirmed.