First Chicago Corp. v. Commissioner
United States Tax Court
A capital loss carryback and an investment credit carryback, both from 1974, were properly allowed with respect to petitioner's taxable year 1971. Respondent subsequently determined a deficiency in petitioner's minimum tax for 1972 on the basis that a sec. 56(c), I.R.C. 1954, "tax carryover" from 1971, which had previously been used by petitioner in computing its 1972 minimum tax, should be reduced on account of the decrease in its income tax for 1971 resulting from the…
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A capital loss carryback and an investment credit carryback, both from 1974, were properly allowed with respect to petitioner's taxable year 1971. Respondent subsequently determined a deficiency in petitioner's minimum tax for 1972 on the basis that a sec. 56(c), I.R.C. 1954, "tax carryover" from 1971, which had previously been used by petitioner in computing its 1972 minimum tax, should be reduced on account of the decrease in its income tax for 1971 resulting from the carrybacks. The statutory notice of deficiency was issued more than 3 years after the return for 1972 had been filed.…
1Opinion of the Court
First Chicago Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent
First Chicago Corp. v. Commissioner
Docket No. 10037-78
United States Tax Court
80 T.C. 648; 1983 U.S. Tax Ct. LEXIS 99; 80 T.C. No. 31;
April 6, 1983, Filed
A capital loss carryback and an investment credit carryback, both from 1974, were properly allowed with respect to petitioner's taxable year 1971. Respondent subsequently determined a deficiency in petitioner's minimum tax for 1972 on the basis that a sec. 56(c), I.R.C. 1954, "tax carryover" from 1971, which had previously been used by petitioner in computing…
Also in this document: Concurrence; Dissent.
2Cases cited12 opinions
- Pesch v. CommissionerUnited States Tax Court · 1982
- Leuthesser v. CommissionerUnited States Tax Court · 1952
- Warrensburg Bd. & Paper Corp. v. CommissionerUnited States Tax Court · 1981
- Bouchey v. CommissionerUnited States Tax Court · 1953
- Maxcy v. CommissionerUnited States Tax Court · 1973
7 more not listed; retrieve them via the Exa API.