LTV Corp. v. Commissioner
United States Tax Court
Petitioner claims and respondent now concedes consolidated net operating losses for 1968 and 1969 sufficient to eliminate the deficiencies determined by respondent for the tax years 1965 and 1966. Disagreement continues over the amount of the pre-carryback deficiency for 1965 and 1966, the precise amount of the consolidated net operating loss attributable to 1968 and to 1969, and the amount of the 1968 and 1969 losses which must be used to eliminate the deficiencies for 1965…
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Petitioner claims and respondent now concedes consolidated net operating losses for 1968 and 1969 sufficient to eliminate the deficiencies determined by respondent for the tax years 1965 and 1966. Disagreement continues over the amount of the pre-carryback deficiency for 1965 and 1966, the precise amount of the consolidated net operating loss attributable to 1968 and to 1969, and the amount of the 1968 and 1969 losses which must be used to eliminate the deficiencies for 1965 and 1966. Held, respondent's concession does not deprive the Court of jurisdiction under sec. 6214 to resolve the…
1Opinion of the Court
OPINION
Wilbur, Judge:
Respondent has determined deficiencies in petitioner’s income tax for the taxable years 1965 and 1966 of $3,735,081.11 and $7,622,261.09. In its petition for redetermination, petitioner alleged numerous errors on the part of respondent, including the disallowance of consolidated net operating losses of $16,981,402, for petitioner’s taxable year 1968 and of $62,354,518, for petitioner’s taxable year 1969. Respondent’s answer denied the existence of any net operating loss for 1968 and 1969.
While the parties continue to disagree on the magnitude of the 1968 and 1969 losses,…
2Cases cited11 opinions
- California v. San Pablo & Tulare RailroadSupreme Court of the United States · 1893
- Local No. 8-6, Oil, Chemical & Atomic Workers International Union v. MissouriSupreme Court of the United States · 1960
- Re Metropolitan Railway ReceivershipSupreme Court of the United States · 1908
- Burns, Stix Friedman & Co. v. CommissionerUnited States Tax Court · 1971
- Hannan v. CommissionerUnited States Tax Court · 1969
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3Cited by117 opinions
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- Charlotte's Office Boutique, Inc. v. Comm'rUnited States Tax Court · 2003
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