Day v. Commissioner
United States Tax Court
R determined deficiencies in Ps' Federal income tax for the years 1988 through 1990. Ps seek to augment the amount of sec. 29, I.R.C., nonconventional fuel source credits they may take against regular income tax by increasing the availability of such credits under the sec. 29(b) (5), I.R.C., limitation.
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R determined deficiencies in Ps' Federal income tax for the years 1988 through 1990. Ps seek to augment the amount of sec. 29, I.R.C., nonconventional fuel source credits they may take against regular income tax by increasing the availability of such credits under the sec. 29(b) (5), I.R.C., limitation. Ps argue that if their taxable income in each year had not been reduced by tax preference items, the resulting tax payable on that income would nonetheless have been the same due to sec. 29, I.R.C., credits generated in these years. R contends that relief under the sec. 59(g), I.R.C., tax…
1Opinion of the Court
OPINION
Nims, Judge:*
Respondent determined deficiencies in Roy E. and Linda Day’s (petitioners or the Days) Federal income tax for the taxable years 1988, 1989, and 1990 in the amounts of $6,791, $14,825, and $10,127, respectively. The only issue for decision is whether petitioners can utilize section 59(g) to compute their tentative minimum taxable income, thereby increasing the extent to which they can apply qualified section 29 credits against their regular income tax for the taxable years 1988 through 1990. For the reasons that follow, we hold that they cannot.
For ready reference, the…
2Cases cited6 opinions
- First Chicago Corporation v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1988
- First Chicago Corp. v. CommissionerUnited States Tax Court · 1987
- E.I. Du Pont de Nemours & Co. v. CommissionerUnited States Tax Court · 1994
- Breakell v. CommissionerUnited States Tax Court · 1991
- Conoco, Inc. v. CommissionerCourt of Appeals for the Fifth Circuit · 1995
1 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Allen v. Comm'rUnited States Tax Court · 2002
- Allen v. Comm'rUnited States Tax Court · 2002
- Charles C. Allen, III and Barbara N. Allen v. CommissionerUnited States Tax Court · 2002
- Day v. CommissionerUnited States Tax Court · 1997
- Roy E. and Linda Day v. CommissionerUnited States Tax Court · 1997