Legal Opinion

Marandola v. United States

United States Court of Federal Claims

Decided April 4, 2007No. 05-252TPublishedCited by 6 opinions

1Opinion of the Court

OPINION AND ORDER

LETTOW, Judge.

Edward and Carmen Marandola (“the taxpayers”) seek a refund for federal income taxes they paid attributable to tax years 1996 through 1999. By amending income tax returns for tax years 1997 through 1999, Mr. Marandola attempted to elect a tax accounting method available to a “trader in securities.” See 26 U.S.C. (“I.R.C.”) § 475(f). The changes Mr. Marandola sought to make, if allowed, would generate refunds of taxes paid by Mr. Marandola for 1997 through 1999 and would create a net operating loss which, when “carried back” to the 1996 tax year, see I.R.C. §…

2Cases cited50 opinions

  1. Steel Co. v. Citizens for a Better EnvironmentSupreme Court of the United States · 1998
  2. Skidmore v. Swift & Co.Supreme Court of the United States · 1944
  3. McNutt v. General Motors Acceptance Corp.Supreme Court of the United States · 1936
  4. United States v. Mead Corp.Supreme Court of the United States · 2001
  5. Karen S. Reynolds v. Army and Air Force Exchange ServiceCourt of Appeals for the Federal Circuit · 1988

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3Cited by6 opinions

  1. Marandola v. United StatesCourt of Appeals for the Federal Circuit · 2008
  2. Heger v. United StatesUnited States Court of Federal Claims · 2012
  3. Dominion Resources, Inc. v. United StatesUnited States Court of Federal Claims · 2011
  4. Larson v. United StatesUnited States Court of Federal Claims · 2009
  5. Holmes v. United StatesUnited States Court of Federal Claims · 2011

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