Intermet Corp. & Subsidiaries v. Commissioner
United States Tax Court
P is the common parent of an affiliated group of corporations (the group) that included L during the period from 1984 to 1993. Pursuant to sec. 172(b)(1)(C), I.R.C., P seeks to carry back, to 1984, certain expenses incurred by L during 1992. For 1992 the group had a consolidated net operating loss as defined in sec. 1.1502-21A(f), Income Tax Regs., and L had separate taxable income as defined in sec. 1.1502-12, Income Tax Regs.
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P is the common parent of an affiliated group of corporations (the group) that included L during the period from 1984 to 1993. Pursuant to sec. 172(b)(1)(C), I.R.C., P seeks to carry back, to 1984, certain expenses incurred by L during 1992. For 1992 the group had a consolidated net operating loss as defined in sec. 1.1502-21A(f), Income Tax Regs., and L had separate taxable income as defined in sec. 1.1502-12, Income Tax Regs. HELD: The expenses in issue do not qualify for the 10-year carryback provided in sec. 172(b)(1)(C), I.R.C., because the expenses do not qualify as specified liability…
1Opinion of the Court
Wells, Judge-.
Respondent determined a deficiency in petitioner Intermet Corp.’s (Intermet) Federal income tax in the amount of $615,019 for 1984. The deficiency arose out of respondent’s disallowance of Intermet’s specified liability loss carryback from 1992 to 1984. After concessions by petitioner, the issues to be decided are: (1) Whether, for purposes of the 10-year carryback provided in section 172(b)(1)(C), certain expenditures incurred by Lynchburg Foundry Co. (Lynch-burg), a member of the Intermet consolidated group, qualify as “specified liability loss” within the meaning of section…
2Cases cited6 opinions
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
- Norwest Corp. v. Comm'rUnited States Tax Court · 1998
- Sealy Corp. v. CommissionerUnited States Tax Court · 1996
- Amtel, Inc. v. StatesUnited States Court of Federal Claims · 1994
1 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Intermet Corporation & Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2000
- Intermet Corp. v. Comm'rUnited States Tax Court · 2001
- Intermet Corp. & Subsidiaries v. CommissionerUnited States Tax Court · 1998
- Intermet Corp. v. Comm'rUnited States Tax Court · 2001
- Intermet Corporation & Subsidiaries v. CommissionerUnited States Tax Court · 2001
2 more not listed; retrieve them via the Exa API.