Legal Opinion

Holden v. Commissioner

United States Tax Court

Decided February 10, 1992No. Docket No. 21102-89Published

When Ps originally filed their 1980 tax return, they were not liable for alternative minimum tax. In 1983, Ps sustained a net operating loss which they carried back as a deduction under sec. 172(a), I.R.C., to 1980. Ps argue that they should not be required to recalculate their alternative minimum tax for 1980 to take into account the net operating loss carryback from 1983. Held, Ps must take into account the net operating loss deduction in recomputing their alternative…

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When Ps originally filed their 1980 tax return, they were not liable for alternative minimum tax. In 1983, Ps sustained a net operating loss which they carried back as a deduction under sec. 172(a), I.R.C., to 1980. Ps argue that they should not be required to recalculate their alternative minimum tax for 1980 to take into account the net operating loss carryback from 1983. Held, Ps must take into account the net operating loss deduction in recomputing their alternative minimum tax liability for 1980.

1Opinion of the Court

Leonard J. and Sadie Holden, Petitioners v. Commissioner of Internal Revenue, Respondent

Holden v. Commissioner

Docket No. 21102-89

United States Tax Court

98 T.C. 160; 1992 U.S. Tax Ct. LEXIS 16; 98 T.C. No. 13;

February 10, 1992, Filed

Decision will be entered for respondent.

When Ps originally filed their 1980 tax return, they were not liable for alternative minimum tax. In 1983, Ps sustained a net operating loss which they carried back as a deduction under sec. 172(a), I.R.C., to 1980. Ps argue that they should not be required to recalculate their alternative minimum tax for 1980 to take into…

2Cases cited2 opinions

  1. Samuel Okin v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987
  2. Holden v. CommissionerUnited States Tax Court · 1992

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