ARC Electrical Constr. Co. v. Commissioner
United States Tax Court
R allowed P a tentative new jobs credit of $ 100,000 for 1977. On its 1977 return, P fraudulently overstated cost of goods sold and reported a tax liability (before credits) of $ 44,324. P utilized $ 44,324 of the new jobs credit in 1977 and claimed a tentative carryback of the $ 55,676 balance to 1974. P also suffered a $ 6 million embezzlement loss in 1980, which could be carried back to 1977. P moved to vacate our decision entered with respect to the 1974 taxable year.
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R allowed P a tentative new jobs credit of $ 100,000 for 1977. On its 1977 return, P fraudulently overstated cost of goods sold and reported a tax liability (before credits) of $ 44,324. P utilized $ 44,324 of the new jobs credit in 1977 and claimed a tentative carryback of the $ 55,676 balance to 1974. P also suffered a $ 6 million embezzlement loss in 1980, which could be carried back to 1977. P moved to vacate our decision entered with respect to the 1974 taxable year. We previously held in part that since P fraudulently understated its taxable income in 1977 due to overstating its cost of…
1Opinion of the Court
ARC ELECTRICAL CONSTRUCTION CO., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ARC Electrical Constr. Co. v. Commissioner
Docket No. 20563-82
United States Tax Court
T.C. Memo 1990-30; 1990 Tax Ct. Memo LEXIS 30; 58 T.C.M. (CCH) 1235; T.C.M. (RIA) 90030;
January 17, 1990
R allowed P a tentative new jobs credit of $ 100,000 for 1977. On its 1977 return, P fraudulently overstated cost of goods sold and reported a tax liability (before credits) of $ 44,324. P utilized $ 44,324 of the new jobs credit in 1977 and claimed a tentative carryback of the $ 55,676 balance to 1974. P also suffered…
2Cases cited6 opinions
- Auerbach Shoe Co. v. CommissionerUnited States Tax Court · 1953
- Auerbach Shoe Company v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1954
- Andrew Toussaint and Isela C. Toussaint v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1984
- Petterson v. CommissionerUnited States Tax Court · 1952
- Toussaint v. CommissionerUnited States Tax Court · 1984
1 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Estate of Trompeter v. CommissionerUnited States Tax Court · 1998
- Arc Electrical Construction Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1991
- Krause v. CommissionerUnited States Tax Court · 1991
- Callahan v. CommissionerUnited States Tax Court · 1992
- Estate of Emanuel Trompeter, Robin Carol Trompeter Gonzalez and Janet Ilene Trompeter Polacheck, Co-Executors v. CommissionerUnited States Tax Court · 1998
6 more not listed; retrieve them via the Exa API.