Legal Opinion

Charles Schwab Corp. v. Comm'r

United States Tax Court

Decided September 29, 2004No. 16903-98; No. 18095-98Published

In an earlier opinion, Charles Schwab Corp. v. Commissioner , 122 T.C. 191 (2004) (Schwab II), we held that sec. 461(d), I.R.C., applied to a 1972 change in California (Cal.) franchise tax law. R contended that if sec. 461(d), I.R.C., applied, P would not be entitled to the $ 932,979 Cal. franchise tax deduction it had claimed for its 1989 Federal tax year. P contended that sec. 461(d), I.R.C., did not apply and that it was entitled to a $ 1,806,588 deduction.

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In an earlier opinion, Charles Schwab Corp. v. Commissioner , 122 T.C. 191 (2004) (Schwab II), we held that sec. 461(d), I.R.C., applied to a 1972 change in California (Cal.) franchise tax law. R contended that if sec. 461(d), I.R.C., applied, P would not be entitled to the $ 932,979 Cal. franchise tax deduction it had claimed for its 1989 Federal tax year. P contended that sec. 461(d), I.R.C., did not apply and that it was entitled to a $ 1,806,588 deduction. P, on its Federal returns for the years under consideration, claimed franchise tax deductions under Cal. law without considering the…

1Opinion of the Court

THE CHARLES SCHWAB CORPORATION AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent *

Charles Schwab Corp. v. Comm'r

No. 16903-98; No. 18095-98

United States Tax Court

123 T.C. 306; 2004 U.S. Tax Ct. LEXIS 46; 123 T.C. No. 18;

September 29, 2004, Filed

Charles Schwab Corp. v. Commissioner, 122 T.C. 191, 2004 U.S. Tax Ct. LEXIS 10 (2004)

Petitioner was entitled to $ 932,979 California franchise tax deduction.

In an earlier opinion,

Charles Schwab Corp. v. Commissioner , 122 T.C. 191 (2004) (Schwab II), we held that

sec. 461(d), I.R.C., applied to a 1972 change in California

(Cal.)…

2Cases cited4 opinions

  1. Charles Schwab Corp. v. CommissionerUnited States Tax Court · 1996
  2. Central Inv. Corp. v. CommissionerUnited States Tax Court · 1947
  3. Charles Schwab Corp. v. Comm'rUnited States Tax Court · 2004
  4. Charles Schwab Corp. v. Comm'rUnited States Tax Court · 2004

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