E.I. Du Pont de Nemours & Co. v. Commissioner
United States Tax Court
In 1982, tax preference items were generally subject to a minimum tax under sec. 56, I.R.C., which was an add-on to the regular income tax. Ps had such preferences, which reduced their taxable income. Because of an abundance of tax credits, however, Ps' liability for regular tax would have been the same even if the preferences had not been used to reduce taxable income.
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In 1982, tax preference items were generally subject to a minimum tax under sec. 56, I.R.C., which was an add-on to the regular income tax. Ps had such preferences, which reduced their taxable income. Because of an abundance of tax credits, however, Ps' liability for regular tax would have been the same even if the preferences had not been used to reduce taxable income. Thus, the preferences did not provide a current tax benefit, and sec. 58(h), I.R.C., relating to the tax benefit rule and the minimum tax, relieved Ps of minimum tax liability for 1982. First Chicago Corp. v. Commissioner, 88…
1Opinion of the Court
OPINION
Hamblen, Chief Judge:
Respondent determined the following deficiencies in the Federal income taxes of E.I. du Pont de Nemours & Co. (Du Pont) and affiliated corporations; Con-oco, Inc. (Conoco), and affiliated corporations; Remington Arms Co., Inc. (Remington); and New England Nuclear Corp. (NEN):
Taxpayer(s) TYE Deficiency
Du Pont, et al. Dec. 31, 1979 $13,010,040
Conoco, et al. Dec. 31, 1980 12,436,199
Remington Jan. 31, 1980 78,698
NEN Feb. 28, 1981 108,196
Total 25,633,133
Unless otherwise indicated, section references are to the Internal Revenue Code in effect during the years in issue…
2Cases cited16 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- United States v. CorrellSupreme Court of the United States · 1967
- Bingler v. JohnsonSupreme Court of the United States · 1969
- United States v. CartwrightSupreme Court of the United States · 1973
- National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
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