Legal Opinion

J. A. Tobin Constr. Co. v. Commissioner

United States Tax Court

Decided December 18, 1985No. Docket No. 10063-82PublishedCited by 12 opinions

The availability of loss carryforwards and loss carrybacks of members of an affiliated group to offset separate income of other members of the affiliated group determined. Respondent's adjustment under sec. 482, I.R.C. 1954, for imputed interest income rejected.

1Opinion of the Court

Swift, Judge:

Respondent determined a deficiency in petitioner’s Federal income tax liability for the year 1975 in the amount of $306,958.67. The parties have reached a partial settlement and the remaining issues for the Court to decide concern the loss carryback and loss carryforward rules of the consolidated return regulations and the validity of certain adjustments made under section 4821 for imputed interest income.

Although the tax deficiency involved herein pertains only to the Federal corporate income tax liability of J.A. Tobin Construction Co., Inc. (Tobin Construction) for 1975, the…

2Cases cited26 opinions

  1. Fin Hay Realty Co. v. United StatesCourt of Appeals for the Third Circuit · 1968
  2. Foster v. Comm'rUnited States Tax Court · 1983
  3. Riss v. CommissionerUnited States Tax Court · 1971
  4. Alterman Foods, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1975
  5. Riss v. CommissionerUnited States Tax Court · 1971

21 more not listed; retrieve them via the Exa API.

3Cited by12 opinions

  1. New York Times Sales, Inc. v. Commissioner of RevenueMassachusetts Appeals Court · 1996
  2. Amorient, Inc. v. CommissionerUnited States Tax Court · 1994
  3. United Parcel Service General Services Co. v. Director, Division of TaxationNew Jersey Tax Court · 2009
  4. TAIYO HAWAII CO. v. COMMISSIONERUnited States Tax Court · 1997
  5. Cepeda v. CommissionerUnited States Tax Court · 1993

7 more not listed; retrieve them via the Exa API.

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