Fruit of the Loom v. Commissioner
United States Tax Court
Following R's audit of P's 1964-68 taxable years, R and P agreed that P was not entitled to the $ 19 million reduction in sale price reported for 1966, but that P could claim $ 15.2 million of this reduction as a loss for 1967. The agreement was reflected on a Form 870, Waiver of Restrictions on Assessment and Collection of Deficiency in Tax and Acceptance of Overassessment, that listed deficiencies for 1965, 1966, and 1968 aggregating $ 10,529,835, and overassessments for…
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Following R's audit of P's 1964-68 taxable years, R and P agreed that P was not entitled to the $ 19 million reduction in sale price reported for 1966, but that P could claim $ 15.2 million of this reduction as a loss for 1967. The agreement was reflected on a Form 870, Waiver of Restrictions on Assessment and Collection of Deficiency in Tax and Acceptance of Overassessment, that listed deficiencies for 1965, 1966, and 1968 aggregating $ 10,529,835, and overassessments for 1964 and 1967 aggregating $ 6,469,651. The Form 870 stated that R could not assess the deficiencies until R scheduled the…
1Opinion of the Court
FRUIT OF THE LOOM, INC., TRANSFEREE OF THE ASSETS OF, AND PRIMARILY LIABLE AS SUCCESSOR BY MERGER TO, NORTHWEST INDUSTRIES, INC., TRANSFEREE OF THE ASSETS OF, AND PRIMARILY LIABLE AS SUCCESSOR BY MERGER TO, PHILADELPHIA & READING CORPORATION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Fruit of the Loom v. Commissioner
Docket No. 26234-92
United States Tax Court
T.C. Memo 1994-492; 1994 Tax Ct. Memo LEXIS 494; 68 T.C.M. (CCH) 867;
October 6, 1994, Filed
Decision will be entered for petitioner.
Following R's audit of P's 1964-68 taxable years, R and P agreed that P was not entitled to…
2Cases cited31 opinions
- Rothensies v. Electric Storage Battery Co.Supreme Court of the United States · 1946
- United States v. SanchezSupreme Court of the United States · 1950
- Borchers v. CommissionerUnited States Tax Court · 1990
- Richard J. Borchers Jane E. Borchers v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1991
- Kavanagh v. NobleSupreme Court of the United States · 1948
26 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Fruit of the Loom, Inc. v. CommissionerCourt of Appeals for the Seventh Circuit · 1996
- Fruit Of The Loom, Incorporated v. Commissioner Of Internal RevenueCourt of Appeals for the Seventh Circuit · 1996
- Brummett v. United StatesDistrict Court, D. Oregon · 2002