Hallmark Cards, Incorporated and Subsidiaries v. Commissioner

111 T.C. No. 14

UNITED STATES TAX COURT HALLMARK CARDS, INCORPORATED AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 27306-92. Filed October 30, 1998. In a decision which has become final, this Court determined that P had an overpayment of Federal income tax for the taxable year 1987, due to a foreign tax carryback from 1989. Prior to the application of the carryback, P had a deficiency for 1987. P filed a timely motion to redetermine interest under sec. 7481(c), I.R.C. Thereafter, P filed a motion for leave to withdraw its earlier motion on…