ESTATE OF QUICK v. COMMISSIONER
United States Tax Court
Ps filed a Motion for Reconsideration of our Opinion reported as Estate of Quick v. Commissioner, 110 T.C. 172 (1998). Among other things, Ps argue that our failure therein to order refunds for overpayments of tax for Ps' 1989 and 1990 tax years stemming from the "proper" computational adjustments which R should have made for those years, as well as refunds for overpayments for their 1987 and 1988 tax years attributable to NOL carrybacks from 1989 and 1990, was erroneous.
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Ps filed a Motion for Reconsideration of our Opinion reported as Estate of Quick v. Commissioner, 110 T.C. 172 (1998). Among other things, Ps argue that our failure therein to order refunds for overpayments of tax for Ps' 1989 and 1990 tax years stemming from the "proper" computational adjustments which R should have made for those years, as well as refunds for overpayments for their 1987 and 1988 tax years attributable to NOL carrybacks from 1989 and 1990, was erroneous. HELD: Ps' Motion for Reconsideration is denied; this Court has jurisdiction to determine overpayments of tax, if any,…
1Opinion of the Court
SUPPLEMENTAL OPINION
Nims, Judge:
In a timely filed motion for reconsideration (motion) pursuant to Rule 161, petitioners request the Court to reconsider its opinion reported as Estate of Quick v. Commissioner, 110 T.C. 172 (1998). The opinion is incorporated herein by this reference.
Except where otherwise noted, all Rule references are to the Tax Court Rules of Practice and Procedure. All section references are to sections of the Internal Revenue Code in effect for the years in issue.
In our opinion, we held, among other things, that respondent’s recharacterization of petitioners’ distributive…
2Cases cited9 opinions
- Naftel v. CommissionerUnited States Tax Court · 1985
- Pyo v. CommissionerUnited States Tax Court · 1984
- Cwt Farms, Inc. And Cwt International, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1985
- Judge v. CommissionerUnited States Tax Court · 1987
- Westbrook v. CommissionerCourt of Appeals for the Fifth Circuit · 1995
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