Legal Opinion
Flood v. United States
District Court, D. Alaska
Decided March 12, 1993No. A92-046-CIVILPublishedCited by 5 opinions
1Opinion of the Court
ORDER
SEDWICK, District Judge.
Plaintiffs James J. Flood and Joan L. Flood bring this action to recover a tax refund of $94,966 plus interest for the 1988 tax year. The parties have submitted the sole issue in this case, whether the Floods may carry forward investment interest deductions in excess of their taxable income under 26 U.S.C. (IRC) § 168(d), for summary judgment based on stipulated facts. 1
I. FACTS
Plaintiffs carried forward excess investment interest from tax years 1983-1986, totaling $1,252,968. Stipulation of Facts (Docket No. 12), at ¶ 6. In 1987, plaintiffs’ net investment…
2Cases cited7 opinions
- Garcia v. United StatesSupreme Court of the United States · 1985
- Sullivan v. FinkelsteinSupreme Court of the United States · 1990
- Federal Power Commission v. Memphis Light, Gas & Water DivisionSupreme Court of the United States · 1973
- Estate of Gerald L. Wallace, Deceased, Celia A. Wallace, and Celia A. Wallace v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1992
- Arthur Beyer Catherine A. Beyer v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1990
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3Cited by5 opinions
- Jeffrey G. Sharp v. United StatesCourt of Appeals for the Federal Circuit · 1994
- James J. Flood Joan L. Flood v. United StatesCourt of Appeals for the Ninth Circuit · 1994
- Haas v. United StatesDistrict Court, W.D. Michigan · 1994
- Jeffrey G. Sharp v. United StatesCourt of Appeals for the Federal Circuit · 1994
- Jeffrey G. Sharp v. United StatesCourt of Appeals for the Federal Circuit · 1994