Legal Opinion

Craigie, Inc. v. Commissioner

United States Tax Court

Decided March 19, 1985No. Docket No. 21240-80PublishedCited by 5 opinions

For the taxable years 1971 through July 24, 1975, petitioner was a member of an affiliated group of corporations filing consolidated returns. On the consolidated return for 1973, Fidelity the common parent, claimed a deduction of $ 22,172,534 for an investment loss. On examination of the return, respondent disallowed the claimed loss as a deduction for 1973 and issued a notice of deficiency.

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For the taxable years 1971 through July 24, 1975, petitioner was a member of an affiliated group of corporations filing consolidated returns. On the consolidated return for 1973, Fidelity the common parent, claimed a deduction of $ 22,172,534 for an investment loss. On examination of the return, respondent disallowed the claimed loss as a deduction for 1973 and issued a notice of deficiency. By signing a statutory notice statement-waiver (Form 4089) on Mar. 26, 1980, Fidelity agreed that the loss was not deductible for 1973. Petitioner did not sign or agree to the execution of the waiver. For…

1Opinion of the Court

Featherston, Judge:

This case was assigned to Special Trial Judge Hu S. Vandervort pursuant to section 74561 and Rules 180 and 181. The Court agrees with and adopts his opinion which is set forth below.

OPINION OF THE SPECIAL TRIAL JUDGE

Vandervort, Special Trial Judge: This case is before the Court on petitioner’s motion for partial summary judgment, filed on February 24, 1984, pursuant to Rule 121.

In the notice of deficiency issued to petitioner on August 26, 1980, respondent determined deficiencies in petitioner’s Federal income tax as follows:

Year Deficiency

1975. $90,569

(July 24 — Dec. 31)

197…

2Cases cited9 opinions

  1. Jacklin v. CommissionerUnited States Tax Court · 1982
  2. Charles Ilfeld Co. v. HernandezSupreme Court of the United States · 1934
  3. Shiosaki v. CommissionerUnited States Tax Court · 1974
  4. Georgia-Pacific Corp. v. CommissionerUnited States Tax Court · 1975
  5. Union Electric Company of Missouri v. The United StatesUnited States Court of Claims · 1962

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

3Cited by5 opinions

  1. Brown-Forman Corp. v. CommissionerUnited States Tax Court · 1990
  2. Malone & Hyde, Inc.United States Tax Court · 1992
  3. Brown-Forman Corp. v. CommissionerUnited States Tax Court · 1990
  4. Craigie, Inc. v. CommissionerUnited States Tax Court · 1985
  5. Grove Equity v. CommissionerUnited States Tax Court · 1994

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