Bankamerica Corp. v. Commissioner
United States Tax Court
P had deficiencies in its Federal income tax for years 1 and 2. In year 3, P carried back an amount of investment tax credit to years 1 and 2, reducing the amount of its deficiencies. In year 6, a net operating loss arose which was carried back to year 3. The carryback of the year 6 loss displaced a year 3 foreign tax credit, which was then carried back to years 1 and 2, displacing the investment tax credit originally taken in those years.
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P had deficiencies in its Federal income tax for years 1 and 2. In year 3, P carried back an amount of investment tax credit to years 1 and 2, reducing the amount of its deficiencies. In year 6, a net operating loss arose which was carried back to year 3. The carryback of the year 6 loss displaced a year 3 foreign tax credit, which was then carried back to years 1 and 2, displacing the investment tax credit originally taken in those years. R computed interest under sec. 6601, I.R.C., from the end of year 3 to the due date of the return for year 6 on deficiency amounts for years 1 and 2,…
1Opinion of the Court
BANKAMERICA CORPORATION, as successor in interest to CONTINENTAL BANK CORPORATION, as successor in interest to CONTINENTAL ILLINOIS CORPORATION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent *
Bankamerica Corp. v. Commissioner
Docket No. 5931-83
United States Tax Court
109 T.C. 1; 1997 U.S. Tax Ct. LEXIS 45; 109 T.C. No. 1;
July 15, 1997, Filed
P had deficiencies in its Federal income tax for years 1 and 2. In year 3, P carried back an amount of investment tax credit to years 1 and 2, reducing the amount of its deficiencies. In year 6, a net operating loss arose which was carried back…
2Cases cited25 opinions
- Hanover Bank v. CommissionerSupreme Court of the United States · 1962
- Callen v. Pennsylvania RailroadSupreme Court of the United States · 1948
- Manning v. Seeley Tube & Box Co.Supreme Court of the United States · 1950
- Ben Abatti and Margaret Abatti v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1988
- Woods v. CommissionerUnited States Tax Court · 1989
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