General Signal Corp. v. Commissioner
United States Tax Court
By motion, P seeks certification of an interlocutory order pursuant to sec. 7482(a)(2), I.R.C., for purposes of appealing the decision set forth in General Signal Corp. v. Commissioner, 103 T.C. 216 (1994). In General Signal Corp., we denied a substantial portion of P's claimed deductions for 1986 and 1987 relating to contributions made to a voluntary employees beneficiary association (VEBA) trust.
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By motion, P seeks certification of an interlocutory order pursuant to sec. 7482(a)(2), I.R.C., for purposes of appealing the decision set forth in General Signal Corp. v. Commissioner, 103 T.C. 216 (1994). In General Signal Corp., we denied a substantial portion of P's claimed deductions for 1986 and 1987 relating to contributions made to a voluntary employees beneficiary association (VEBA) trust. A final decision as to petitioner's 1986 and 1987 taxable years cannot be entered as of this time because a carryback deduction from a subsequent year has also been placed in issue. At present, the…
1Opinion of the Court
supplemental opinion
Nims, Judge:
On August 22, 1994, the Court filed an opinion at 103 T.C. 216, in which several, but not all, issues were decided. On December 21, 1994, petitioner filed a motion for certification for interlocutory appeal (petitioner’s motion). Petitioner moves the Court, pursuant to Rule 193, for an order modifying the opinion to include a finding that the issues addressed in the opinion involve controlling questions of law with respect to which there is substantial ground for difference of opinion and that an immediate appeal may materially advance the ultimate termination…
2Cases cited7 opinions
- Coopers & Lybrand v. LivesaySupreme Court of the United States · 1978
- Westwood Pharmaceuticals, Inc. v. National Fuel Gas Distribution CorporationCourt of Appeals for the Second Circuit · 1992
- United States v. Ray B. WoodburyCourt of Appeals for the Ninth Circuit · 1959
- Midland Mortg. Co. v. CommissionerUnited States Tax Court · 1980
- General Signal Corp. v. CommissionerUnited States Tax Court · 1994
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