Intermet Corp. v. Comm'r
United States Tax Court
In Intermet Corp. & Subs. v. Commissioner, 209 F.3d 901 (6th Cir. 2000), revg. and remanding 111 T.C. 294 (1998), the Court of Appeals remanded this case to the Court to determine whether amounts that P paid to satisfy its State tax liabilities and interest on Federal and State tax liabilities, qualify as "specified liability losses" within the meaning of sec. 172(f)(1)(B), I.R.C.
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In Intermet Corp. & Subs. v. Commissioner, 209 F.3d 901 (6th Cir. 2000), revg. and remanding 111 T.C. 294 (1998), the Court of Appeals remanded this case to the Court to determine whether amounts that P paid to satisfy its State tax liabilities and interest on Federal and State tax liabilities, qualify as "specified liability losses" within the meaning of sec. 172(f)(1)(B), I.R.C. HELD: P's State tax liabilities and interest on Federal and State tax liabilities qualify as "specified liability losses" within the meaning of sec. 172(f)(1)(B), I.R.C.
1Opinion of the Court
SUPPLEMENTAL OPINION
Wells, Chief Judge:
This case is before the Court on remand from the Court of Appeals for the Sixth Circuit in Intermet Corp. & Subs. v. Commissioner, 209 F.3d 901 (6th Cir. 2000), revg. and remanding 111 T.C. 294 (1998). In Intermet Corp. & Subs. v. Commissioner, supra, the Court of Appeals held that Intermet Corp. and its subsidiaries (hereinafter petitioner) is eligible to carry back for 10 years pursuant to section 172(b)(1)(C) certain expenses, i.e., State tax liabilities and interest on Federal and State tax liabilities, provided that those expenses qualify as…
2Cases cited5 opinions
- Intermet Corporation & Subsidiaries v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2000
- Sealy Corp. v. CommissionerUnited States Tax Court · 1996
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- Host Marriott Corporation v. United States of America, Manufacturers Alliance/mapi Incorporated, Amicus CuriaeCourt of Appeals for the Fourth Circuit · 2001
- Intermet Corp. & Subsidiaries v. CommissionerUnited States Tax Court · 1998
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