Legal Opinion

Intermet Corp. v. Comm'r

United States Tax Court

Decided October 2, 2001No. 8246-97Published

In Intermet Corp. & Subs. v. Commissioner, 209 F.3d 901 (6th Cir. 2000), revg. and remanding 111 T.C. 294 (1998), the Court of Appeals remanded this case to the Court to determine whether amounts that P paid to satisfy its State tax liabilities and interest on Federal and State tax liabilities, qualify as "specified liability losses" within the meaning of sec. 172(f)(1)(B), I.R.C.

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In Intermet Corp. & Subs. v. Commissioner, 209 F.3d 901 (6th Cir. 2000), revg. and remanding 111 T.C. 294 (1998), the Court of Appeals remanded this case to the Court to determine whether amounts that P paid to satisfy its State tax liabilities and interest on Federal and State tax liabilities, qualify as "specified liability losses" within the meaning of sec. 172(f)(1)(B), I.R.C. HELD: P's State tax liabilities and interest on Federal and State tax liabilities qualify as "specified liability losses" within the meaning of sec. 172(f)(1)(B), I.R.C.

1Opinion of the Court

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

Intermet Corp. v. Comm'r

No. 8246-97

United States Tax Court

117 T.C. 133; 2001 U.S. Tax Ct. LEXIS 44; 117 T.C. No. 13;

October 2, 2001, Filed

Decision will be entered pursuant to Rule 155.

In Intermet Corp. & Subs. v. Commissioner, 209 F.3d 901

(6th Cir. 2000), revg. and remanding 111 T.C. 294 (1998), the

Court of Appeals remanded this case to the Court to determine

whether amounts that P paid to satisfy its State tax liabilities

and interest on Federal and State tax liabilities, qualify as

"specified…

2Cases cited6 opinions

  1. Intermet Corporation & Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2000
  2. Sealy Corp. v. CommissionerUnited States Tax Court · 1996
  3. Host Marriott Corp. v. United StatesDistrict Court, D. Maryland · 2000
  4. Intermet Corp. v. Comm'rUnited States Tax Court · 2001
  5. Host Marriott Corporation v. United States of America, Manufacturers Alliance/mapi Incorporated, Amicus CuriaeCourt of Appeals for the Fourth Circuit · 2001

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