Intermet Corporation & Subsidiaries v. Commissioner of Internal Revenue
Court of Appeals for the Sixth Circuit
1Opinion of the Court
OPINION
RYAN, Circuit Judge.
This case requires us to decide whether an affiliated group of corporations filing a consolidated federal income tax return is entitled to a 10-year carryback for certain “specified liability” expenses incurred by a member corporation with positive separate taxable income. We conclude that the 10-year carryback is applicable under this scenario. Therefore, we will REVERSE the judgment of the United States Tax Court and REMAND to that court for further proceedings consistent with this opinion.
I
The relevant facts are undisputed. In-termet Corporation is the common…
2Cases cited16 opinions
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
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- Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
- Northern Indiana Public Service Co. v. Porter County Chapter of Izaak Walton League of America, Inc.Supreme Court of the United States · 1975
- Atlantic Mutual Insurance v. CommissionerSupreme Court of the United States · 1998
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- Intermet Corp. v. Comm'rUnited States Tax Court · 2001
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