Holden v. Commissioner
United States Tax Court
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…
Read the full summary
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
- Samuel Okin v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987
- Holden v. CommissionerUnited States Tax Court · 1992