Legal Opinion

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

United States Tax Court

Decided December 18, 1985No. Docket No. 10063-82Published

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

J. A. Tobin Construction Company, Petitioner v. Commissioner of Internal Revenue, Respondent

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

Docket No. 10063-82

United States Tax Court

85 T.C. 1005; 1985 U.S. Tax Ct. LEXIS 7; 85 T.C. No. 58;

December 18, 1985, Filed

Decision will be entered under Rule 155.

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.

Richard S. Managhan and Ernest M. Fleischer,…

2Cases cited27 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

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