First Chicago Corp. v. Commissioner
United States Tax Court
A capital loss carryback and an investment credit carryback, both from 1974, were properly allowed with respect to petitioner's taxable year 1971. Respondent subsequently determined a deficiency in petitioner's minimum tax for 1972 on the basis that a sec. 56(c), I.R.C. 1954, "tax carryover" from 1971, which had previously been used by petitioner in computing its 1972 minimum tax, should be reduced on account of the decrease in its income tax for 1971 resulting from the…
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A capital loss carryback and an investment credit carryback, both from 1974, were properly allowed with respect to petitioner's taxable year 1971. Respondent subsequently determined a deficiency in petitioner's minimum tax for 1972 on the basis that a sec. 56(c), I.R.C. 1954, "tax carryover" from 1971, which had previously been used by petitioner in computing its 1972 minimum tax, should be reduced on account of the decrease in its income tax for 1971 resulting from the carrybacks. The statutory notice of deficiency was issued more than 3 years after the return for 1972 had been filed.…
1Opinion of the Court
OPINION
Dawson, Judge:
This case is before the Court on respondent’s motion for partial summary judgment and petitioner’s cross-motion for partial summary judgment. These motions are now assigned to Special Trial Judge Fred S. Gilbert, Jr., for consideration and ruling thereon. After reviewing the record, the Court agrees with and adopts his opinion, which is set forth below.1
OPINION OF THE SPECIAL TRIAL JUDGE
Gilbert, Special Trial Judge:
By notice of deficiency mailed June 2, 1978, respondent determined a deficiency in petitioner’s Federal income tax for the taxable year 1972 in the amount of…
2Cases cited6 opinions
- Pesch v. CommissionerUnited States Tax Court · 1982
- Leuthesser v. CommissionerUnited States Tax Court · 1952
- Bouchey v. CommissionerUnited States Tax Court · 1953
- Maxcy v. CommissionerUnited States Tax Court · 1973
- Herman Bennett Co. v. CommissionerUnited States Tax Court · 1975
1 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Electrolux Holdings, Inc. v. United StatesCourt of Appeals for the Federal Circuit · 2007
- Eleanor M. Ballard v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1988
- First Chicago Corporation v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1984
- Electrolux Holdings, Inc. v. United StatesUnited States Court of Federal Claims · 2006
- First Chicago Corp. v. CommissionerUnited States Tax Court · 1983
1 more not listed; retrieve them via the Exa API.