Legal Opinion
John H. Young and Carolyn J. Young v. Commissioner of Internal Revenue
Court of Appeals for the Fifth Circuit
Decided February 26, 1986No. 85-4185PublishedCited by 47 opinions
1Opinion of the Court
PATRICK E. HIGGINBOTHAM, Circuit Judge:
Taxpayers appeal a United States Tax Court decision, 83 T.C. 831, that they failed to make an effective binding election, pursuant to section 172(b)(3)(C) of the Internal Revenue Code, to “carry forward” to 1977 rather than “carry back” to prior years their net operating loss for the 1976 tax year, resulting in a deficiency of $48,722.49 in their 1977 federal income taxes. Because the Tax Court correctly determined that taxpayers neither literally nor substantially complied with the statutory election requirement, we affirm.
' I
In their joint 1976 federal…
2Cases cited10 opinions
- Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
- Reaver v. CommissionerUnited States Tax Court · 1964
- Taylor v. CommissionerUnited States Tax Court · 1977
- Columbia Iron & Metal Co. v. CommissionerUnited States Tax Court · 1973
- Valdes v. CommissionerUnited States Tax Court · 1973
5 more not listed; retrieve them via the Exa API.
3Cited by47 opinions
- Lucille Prussner, as of the Estate of Aileen E. Pfeifer v. United StatesCourt of Appeals for the Seventh Circuit · 1990
- In Re Herbert E. Russell. William Russell Gibson and F.H. Martin, Co-Trustees of the Estate of Herbert E. Russell v. United StatesCourt of Appeals for the Eighth Circuit · 1991
- In Re: James Kenneth FeilerCourt of Appeals for the Ninth Circuit · 2000
- Estate of Higgins v. CommissionerUnited States Tax Court · 1988
- Estate of John T. Higgins, Deceased Manufacturers National Bank of Detroit, Personal Representative v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1990
42 more not listed; retrieve them via the Exa API.