Legal Opinion

Jim Burch & Associates, Inc. v. Commissioner

United States Tax Court

Decided February 3, 1981No. Docket No. 6552-78Published

An affiliated group of corporations incurred consolidated net operating losses, which were attributable solely to petitioner's wholly owned subsidiary. Held, inasmuch as that subsidiary was not a member of the group immediately after its organization, the consolidated net operating loss may not be carried back to the separate return year of petitioner.

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An affiliated group of corporations incurred consolidated net operating losses, which were attributable solely to petitioner's wholly owned subsidiary. Held, inasmuch as that subsidiary was not a member of the group immediately after its organization, the consolidated net operating loss may not be carried back to the separate return year of petitioner. Sec. 1.1502-79(a), Income Tax Regs.Held, further, respondent's determination that part of petitioner's underpayment of tax was due to negligence or intentional disregard of rules and regulations within the purview of sec. 6653(a), I.R.C. 1954,…

1Opinion of the Court

Jim Burch & Associates, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent

Jim Burch & Associates, Inc. v. Commissioner

Docket No. 6552-78

United States Tax Court

76 T.C. 202; 1981 U.S. Tax Ct. LEXIS 179;

February 3, 1981, Filed

Decision will be entered under Rule 155.

An affiliated group of corporations incurred consolidated net operating losses, which were attributable solely to petitioner's wholly owned subsidiary. Held, inasmuch as that subsidiary was not a member of the group immediately after its organization, the consolidated net operating loss may not be carried back to the…

2Cases cited6 opinions

  1. Enoch v. CommissionerUnited States Tax Court · 1972
  2. Pritchett v. CommissionerUnited States Tax Court · 1974
  3. Georgia-Pacific Corp. v. CommissionerUnited States Tax Court · 1975
  4. Leroy Jewelry Co. v. CommissionerUnited States Tax Court · 1961
  5. Electronic Sensing Products, Inc. v. CommissionerUnited States Tax Court · 1977

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