Legal Opinion
Intermet Corporation & Subsidiaries v. Commissioner
United States Tax Court
Decided December 8, 1998No. 8246-97Unknown
1Opinion of the Court
111 T.C. No. 16
UNITED STATES TAX COURT INTERMET CORPORATION & SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8246-97. Filed December 8, 1998. P is the common parent of an affiliated group of corporations (the group) that included L during the period from 1984 to 1993. Pursuant to sec. 172(b)(1)(C), I.R.C., P seeks to carry back, to 1984, certain expenses incurred by L during 1992. For 1992 the group had a consolidated net operating loss as defined in sec. 1.1502-21A(f), Income Tax Regs., and L had separate taxable income as defined in sec. 1.1502- 12,…
2Cases cited7 opinions
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
- Norwest Corp. v. Comm'rUnited States Tax Court · 1998
- Sealy Corp. v. CommissionerUnited States Tax Court · 1996
- Amtel, Inc. v. StatesUnited States Court of Federal Claims · 1994
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