Hallmark Cards v. Commissioner
United States Tax Court
In a decision which has become final, this Court determined that P had an overpayment of Federal income tax for the taxable year 1987, due to a foreign tax carryback from 1989. Prior to the application of the carryback, P had a deficiency for 1987. P filed a timely motion to redetermine interest under sec. 7481(c), I.R.C. Thereafter, P filed a motion for leave to withdraw its earlier motion on jurisdictional grounds.
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In a decision which has become final, this Court determined that P had an overpayment of Federal income tax for the taxable year 1987, due to a foreign tax carryback from 1989. Prior to the application of the carryback, P had a deficiency for 1987. P filed a timely motion to redetermine interest under sec. 7481(c), I.R.C. Thereafter, P filed a motion for leave to withdraw its earlier motion on jurisdictional grounds. HELD, this Court has jurisdiction over P's motion to redetermine interest. HELD, FURTHER, the exercise of such jurisdiction is mandatory, and, thus, P's motion to withdraw is…
1Opinion of the Court
HALLMARK CARDS, INCORPORATED AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Hallmark Cards v. Commissioner
Tax Ct. Dkt. No. 27306-92
United States Tax Court
111 T.C. 266; 1998 U.S. Tax Ct. LEXIS 50; 111 T.C. No. 14;
October 30, 1998, Filed
In a decision which has become final, this Court determined that P had an overpayment of Federal income tax for the taxable year 1987, due to a foreign tax carryback from 1989. Prior to the application of the carryback, P had a deficiency for 1987. P filed a timely motion to redetermine interest under sec. 7481(c), I.R.C. Thereafter,…
2Cases cited7 opinions
- Dorl v. CommissionerUnited States Tax Court · 1972
- Estate of Ming v. CommissionerUnited States Tax Court · 1974
- Powell v. CommissionerUnited States Tax Court · 1991
- Bankamerica Corp. v. CommissionerUnited States Tax Court · 1997
- Coninck v. CommissionerUnited States Tax Court · 1993
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