Hill v. Commissioner
United States Tax Court
Respondent recomputed petitioners' tax liability for a prior year, for which an assessment is barred by the statute of limitations, and, because of an increase in the tax so recomputed, reduced the amount of unused investment credit carried to the year before the Court.
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Respondent recomputed petitioners' tax liability for a prior year, for which an assessment is barred by the statute of limitations, and, because of an increase in the tax so recomputed, reduced the amount of unused investment credit carried to the year before the Court. Held, sec. 6214(b) imposes no jurisdictional bar to the computation of petitioners' pre-credit tax liability for a prior year in order to determine the amount of investment credit used in that year and, thus, unavailable for carryover to the year in issue. Held, further, sec. 6501(a) does not bar respondent from assessing and…
1Opinion of the Court
OPINION
HALPERN, Judge:*
By statutory notice dated July 14, 1988, respondent determined deficiencies in petitioners’ Federal income tax and additions to tax as follows:
Additions to tax
Year Deficiency Sec. 6653(a)(1)1 Sec. 6653(a)(2) Sec. 6661
1982 $45,591.83 $2,795.24 50 percent of interest due on $55,904.832 $13,976.21
1983 7,611.40 964.45 50 percent of interest due on $19,289.402 4,822.25
1984 1,890.00 386.80 50 percent of interest due on $7,736.002 1,934.00
The parties each have made numerous concessions. The only issue remaining for decision is whether respondent may recompute the tax for a…
2Cases cited13 opinions
- Commissioner v. Gooch Milling & Elevator Co.Supreme Court of the United States · 1944
- Lone Manor Farms, Inc. v. CommissionerUnited States Tax Court · 1974
- Mennuto v. CommissionerUnited States Tax Court · 1971
- Calumet Industries, Inc. v. CommissionerUnited States Tax Court · 1990
- Carpenter v. CommissionerUnited States Tax Court · 1948
8 more not listed; retrieve them via the Exa API.
3Cited by40 opinions
- Freije v. Comm'rUnited States Tax Court · 2005
- Capitol Fed. Sav. & Loan Ass'n v. CommissionerUnited States Tax Court · 1991
- Harris v. CommissionerUnited States Tax Court · 1992
- Mecom v. CommissionerUnited States Tax Court · 1993
- G-5 Inv. P'ship v. Comm'rUnited States Tax Court · 2007
35 more not listed; retrieve them via the Exa API.