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
OPINION
Goeke, Judge:
On March 17, 2003, petitioner filed a motion to redetermine interest under section 7481(c) and Rule 261.1 Petitioner, a C corporation, claims that it overpaid interest relating to its income tax liability for its tax year ended January 31, 1994, because respondent erroneously applied the increased interest rate under section 6621(c) (“hot interest”). The substantive issue for decision is whether a net operating loss (NOL) carryback which reduces an underpayment of tax for a preceding year below $100,000 is disregarded for purposes of determining whether a large corporate…
2Cases cited12 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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