Charles Schwab Corp. v. Comm'r
United States Tax Court
P, for Federal tax reporting purposes, claimed a California franchise tax deduction for 1989. Subsequently, P claimed the 1989 deduction for an earlier year and was successful in that claim in prior litigation before this Court.
Read the full summary
P, for Federal tax reporting purposes, claimed a California franchise tax deduction for 1989. Subsequently, P claimed the 1989 deduction for an earlier year and was successful in that claim in prior litigation before this Court. For purposes of these cases, P claims entitlement to franchise tax deductions for 1989 in the amount originally deducted for 1990. In like manner, P claims the franchise tax deductions originally claimed for 1993, 1992, and 1991 are now deductible for the preceding years of 1992, 1991, and 1990, respectively. R contends that sec. 461(d), I.R.C., proscribes such…
1Opinion of the Court
Gerber, Judge:
Respondent, in these consolidated cases,1 determined deficiencies in petitioner’s2 1989, 1990, 1991, and 1992 income taxes of $2,245,332, $2,797,349, $3,101,526, and $827,683, respectively. By means of amended answers, respondent asserts increased income tax deficiencies of $2,644,782, $2,906,015, $3,210,191, and $936,349 for petitioner’s tax years 1989, 1990, 1991, and 1992, respectively.3 The issues presented for our consideration are: (1) Whether section 461(d)4 proscribes certain California franchise tax deductions petitioner claims; (2) whether petitioner’s acquired…
2Cases cited22 opinions
- United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989
- Kimbell-Diamond Milling Co. v. Comm'rUnited States Tax Court · 1950
- Kimbell-Diamond Milling Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
- Estate of Andrews v. CommissionerUnited States Tax Court · 1982
- Propstra v. United StatesCourt of Appeals for the Ninth Circuit · 1982
17 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Deseret Management Corporation v. United StatesUnited States Court of Federal Claims · 2013
- Charles Schwab Corp. v. Comm'rUnited States Tax Court · 2004
- Charles Schwab Corp. v. CommissionerCourt of Appeals for the Ninth Circuit · 2007
- Charles Schwab Corp. v. Comm'rUnited States Tax Court · 2004
- Charles Schwab Corp. v. Comm'rUnited States Tax Court · 2004
2 more not listed; retrieve them via the Exa API.