Wegman's Properties, Inc. v. Commissioner
United States Tax Court
Held, in computing their minimum tax, petitioners may not offset tax carryovers generated by one corporation in preaffiliation years against tax preference items generated by another corporation in consolidated return years.
1Opinion of the Court
OPINION
Tannenwald, Chief Judge:
Respondent determined deficiencies in petitioners’ Federal income tax of $25,883.47 for the taxable year ended June 24, 1972, and $24,023.10 for the taxable year ended June 30, 1973. The sole issue for our determination is whether, for purposes of computing petitioners’ minimum tax liability, tax carryovers generated by one corporation in preaffiliation years1 may be used to offset items of tax preference generated by a second corporation in consolidated return years.
This case was submitted fully stipulated pursuant to Rule 122, Tax Court Rules of Practice and…
2Cases cited11 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Interstate Transit Lines v. CommissionerSupreme Court of the United States · 1943
- National Carbide Corp. v. CommissionerSupreme Court of the United States · 1949
- Woolford Realty Co. v. RoseSupreme Court of the United States · 1932
- Libson Shops, Inc., v. Koehler, District Director of Internal RevenueSupreme Court of the United States · 1957
6 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
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- Applied Research Associates, Inc. & Affiliate v. CommissionerUnited States Tax Court · 2014
- Applied Research Associates, Inc. and Affiliate v. CommissionerUnited States Tax Court · 2014
- Henninger v. CommissionerUnited States Tax Court · 1991
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