Old Harbor Native Corp. v. Commissioner
United States Tax Court
P is an Alaska native village corporation organized under the Alaska Native Claims Settlement Act (ANCSA), Pub. L. 92-203, 85 Stat. 688 (1971) (current version at 43 U.S.C. secs. 1601-1629e (1988)). ANCSA, which was enacted by the Congress to extinguish aboriginal land claims of the Alaskan natives, required the Government to transfer some of its land in Alaska to P. In order to reacquire much of this land, the Government negotiated an agreement with P under which P would…
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P is an Alaska native village corporation organized under the Alaska Native Claims Settlement Act (ANCSA), Pub. L. 92-203, 85 Stat. 688 (1971) (current version at 43 U.S.C. secs. 1601-1629e (1988)). ANCSA, which was enacted by the Congress to extinguish aboriginal land claims of the Alaskan natives, required the Government to transfer some of its land in Alaska to P. In order to reacquire much of this land, the Government negotiated an agreement with P under which P would transfer the land back to the Government in exchange for the subsurface rights in other Government-owned land in Alaska.…
1Opinion of the Court
OPINION
Laro, Judge:
This case is before the Court fully stipulated under Rule 122(a). Old Harbor Native Corp. petitioned the Court to redetermine respondent’s determination of deficiencies of $1,506,888 and $196,563 in its 1987 and 1988 Federal income taxes, respectively. Respondent reflected her determination in a notice of deficiency issued to petitioner on February 10, 1993. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the years in issue. Rule references are to the Tax Court Rules of Practice and Procedure.
Following concessions, we must…
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