Med James, Inc. v. Comm'r
United States Tax Court
R sent P a 30-day letter proposing a deficiency in excess of $ 100,000 for P's tax year ended Jan. 31, 1994. R subsequently issued a notice of deficiency to P determining deficiencies in P's corporate income taxes for its tax years ended Jan. 31, 1994, 1995, and 1996. P filed a petition to this Court.
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R sent P a 30-day letter proposing a deficiency in excess of $ 100,000 for P's tax year ended Jan. 31, 1994. R subsequently issued a notice of deficiency to P determining deficiencies in P's corporate income taxes for its tax years ended Jan. 31, 1994, 1995, and 1996. P filed a petition to this Court. R and P stipulated that P's deficiency in income tax for the tax year ended Jan. 31, 1994, computed before allowance for a net operating loss (NOL) carryback from the subsequent tax year was $ 225,753. After allowance for the NOL carryback, P's deficiency for the tax year ended Jan. 31, 1994,…
1Opinion of the Court
MED JAMES, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Med James, Inc. v. Comm'r
No. 366-01
United States Tax Court
121 T.C. 147; 2003 U.S. Tax Ct. LEXIS 31; 121 T.C. No. 9;
September 9, 2003, Filed
Decision will be entered for petitioner.
R sent P a 30-day letter proposing a deficiency in excess
of $ 100,000 for P's tax year ended Jan. 31, 1994. R subsequently
issued a notice of deficiency to P determining deficiencies in
P's corporate income taxes for its tax years ended Jan. 31,
1994, 1995, and 1996. P filed a petition to this Court. R and P
stipulated that P's deficiency in…
2Cases cited13 opinions
- Manning v. Seeley Tube & Box Co.Supreme Court of the United States · 1950
- Rhi Holdings, Inc. v. United StatesCourt of Appeals for the Federal Circuit · 1998
- LTV Corp. v. CommissionerUnited States Tax Court · 1975
- William H. Kenner and Eleanor v. Kenner v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1968
- Alphonso Bax and Alice Corrine Bax, Deceased, and Alphonso L. Bax, Administrator v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1993
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