Wiggins v. Comm'r
United States Tax Court
Ps included the tax upon recapture of investment credits in determining the amount of their regular tax for purposes of the alternative minimum tax computation. The Deficit Reduction Act of 1984, enacted July 18, 1984, amended sec. 55(f)(2) of the Internal Revenue Code to clarify that the tax upon recapture of investment credits is excluded from regular tax in calculating taxpayers' alternative minimum tax liability.
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Ps included the tax upon recapture of investment credits in determining the amount of their regular tax for purposes of the alternative minimum tax computation. The Deficit Reduction Act of 1984, enacted July 18, 1984, amended sec. 55(f)(2) of the Internal Revenue Code to clarify that the tax upon recapture of investment credits is excluded from regular tax in calculating taxpayers' alternative minimum tax liability. The Deficit Reduction Act of 1984 provided that this amendment is retroactive to tax years beginning after Dec. 31, 1982. Held, the retroactive application of amended sec.…
1Opinion of the Court
OPINION
Nims, Chief Judge:
This case was assigned to Special Trial Judge Norman H. Wolfe pursuant to the provisions of section 7443A(b) 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
WOLFE, Special Trial Judge:
Respondent determined a deficiency in petitioners’ 1983 Federal income tax in the amount of $4,502 and additions to tax under section 6653(a)(1) in the amount of $225.10 and under section 6653(a)(2) of 50 percent of the interest due on $4,502.
After concessions, the two issues…
2Cases cited14 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Neely v. CommissionerUnited States Tax Court · 1985
- Brushaber v. Union Pacific RailroadSupreme Court of the United States · 1916
- Welch v. HenrySupreme Court of the United States · 1938
- Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
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3Cited by14 opinions
- Horace Lynn Wiggins and Jimmie Sue Wiggins v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1990
- Estate of Monroe v. CommissionerUnited States Tax Court · 1995
- Bergersen v. CommissionerUnited States Tax Court · 1995
- Barter Systems, Inc. v. CommissionerUnited States Tax Court · 1990
- TIFD III-E Inc. v. United StatesDistrict Court, D. Connecticut · 2014
9 more not listed; retrieve them via the Exa API.