Murphree v. Commissioner
United States Tax Court
Held, the disallowance of a refundable energy credit under sec. 48(a)(10), I.R.C. 1954, is a deficiency under sec. 6211(a).
1Opinion of the Court
OPINION
STERRETT, Chief Judge:
This case was assigned to Special Trial Judge Carleton D. Powell pursuant to the provisions of section 7456(d) (redesignated as section 7443A by the Tax Reform Act of 1986, Pub. L. 99-514, section 1556, 100 Stat. 2754) and Rule 180 et seq.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
POWELL, Special Trial Judge:
This case is before the Court on respondent’s motion to dismiss for lack of jurisdiction and to strike as to the refundable business energy investment tax credit issue…
2Cases cited3 opinions
- Huntsberry v. CommissionerUnited States Tax Court · 1984
- Martz v. CommissionerUnited States Tax Court · 1981
- Beckman v. United StatesDistrict Court, D. Kansas · 1975
3Cited by9 opinions
- Arc Electrical Construction Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1991
- Estate of Branson v. CommissionerUnited States Tax Court · 1999
- Estate of Branson v. CommissionerUnited States Tax Court · 1999
- Estate of Frank A. Branson v. CommissionerUnited States Tax Court · 1999
- Estate of Mueller v. Comm'rUnited States Tax Court · 1993
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