Legal Opinion

Intermet Corp. & Subsidiaries v. Commissioner

United States Tax Court

Decided December 8, 1998No. Tax Ct. Dkt. No. 8246-97Published

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, Income Tax Regs.

Read the full summary

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, Income Tax Regs. HELD: The expenses in issue do not qualify for the 10-year carryback provided in sec. 172(b)(1)(C), I.R.C., because the expenses do not qualify as specified liability…

1Opinion of the Court

INTERMET CORPORATION & SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Intermet Corp. & Subsidiaries v. Commissioner

Tax Ct. Dkt. No. 8246-97

United States Tax Court

111 T.C. 294; 1998 U.S. Tax Ct. LEXIS 52; 111 T.C. No. 16;

December 8, 1998, Filed

Decision will be entered for respondent.

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…

2Cases cited7 opinions

  1. Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
  2. Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
  3. Norwest Corp. v. Comm'rUnited States Tax Court · 1998
  4. Sealy Corp. v. CommissionerUnited States Tax Court · 1996
  5. Amtel, Inc. v. StatesUnited States Court of Federal Claims · 1994

2 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API