Intel Corp. & Consol. Subsidiaries v. Commissioner
United States Tax Court
INTEL CORPORATION AND CONSOLIDATED SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent *This supplements Intel Corp. v. Commissioner, 100 T.C. 616 (1993), affd. 67 F.3d 1445 (9th Cir. 1995), amended and superseded 76 F.3d 976 (9th Cir. 1996). P had deficiencies in its Federal income tax for the taxable years 1979 and 1980. From the taxable year 1981, P carried back an amount of foreign tax to 1979 and 1980. From 1982, P carried back additional foreign…
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INTEL CORPORATION AND CONSOLIDATED SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent *This supplements Intel Corp. v. Commissioner, 100 T.C. 616 (1993), affd. 67 F.3d 1445 (9th Cir. 1995), amended and superseded 76 F.3d 976 (9th Cir. 1996). P had deficiencies in its Federal income tax for the taxable years 1979 and 1980. From the taxable year 1981, P carried back an amount of foreign tax to 1979 and 1980. From 1982, P carried back additional foreign tax to 1980. R computed interest under sec. 6601, I.R.C. 1954, from the respective due dates of the returns for 1979 and…
1Opinion of the Court
SUPPLEMENTAL OPINION
Tannenwald, Judge:
A decision was entered in this case on December 9, 1993, pursuant to a stipulated computation, in accordance with this Court’s opinion, Intel Corp. v. Commissioner, 100 T.C. 616 (1993), affd. 67 F.3d 1445 (9th Cir. 1995), amended and superseded 76 F.3d 976 (9th Cir. 1996). On May 9, 1997, petitioner filed a motion under section 7481(c)1 and Rule 261 to redetermine interest on the deficiencies for the 1979 and 1980 taxable years.
The parties agree that, for the taxable years 1979 and 1980, petitioner had foreign tax carrybacks from 1981 and 1982 as follows:
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2Cases cited18 opinions
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