Harris v. Commissioner
United States Tax Court
Held, net operating loss carrybacks attributable to settlement of partnership items of a partnership subject to the rules of subchapter C of chapter 63 (the partnership provisions of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub.
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Held, net operating loss carrybacks attributable to settlement of partnership items of a partnership subject to the rules of subchapter C of chapter 63 (the partnership provisions of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, 96 Stat. 324), I.R.C., may be taken into account in redetermining partners' personal tax liability pursuant to Rule 155, Tax Court Rules of Practice and Procedure, in a deficiency proceeding under sec. 6214(b), I.R.C.Held, further, entry of decision in such deficiency proceeding will not be deferred pending resolution of other…
1Opinion of the Court
SUPPLEMENTAL OPINION
Wells, Judge:
The instant matter arises out of a dispute between the parties over their differing computations under Rule 155.1 The issue presented by the parties arose after our memorandum opinion on the merits of the instant case was issued on February 20, 1990, T.C. Memo. 1990-80.2 Petitioner has requested that the Court defer entry of the decision in the instant case in order to avoid the possibility that petitioner might be precluded from carrying back, to the years in issue, certain net operating losses (nol’s) arising out of partnerships subject to sections 6221…
2Cases cited20 opinions
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Helvering v. Stockholms Enskilda BankSupreme Court of the United States · 1934
- Haggar Co. v. Helvering, Com'r of Internal RevenueSupreme Court of the United States · 1940
- Maxwell v. CommissionerUnited States Tax Court · 1986
- Lone Manor Farms, Inc. v. CommissionerUnited States Tax Court · 1974
15 more not listed; retrieve them via the Exa API.
3Cited by39 opinions
- Chai v. CommissionerCourt of Appeals for the Second Circuit · 2017
- Rhone-Poulenc Surfactants & Specialties, L.P. v. CommissionerUnited States Tax Court · 2000
- Bradley v. CommissionerUnited States Tax Court · 1993
- Chimblo v. CommissionerCourt of Appeals for the Second Circuit · 1999
- Brookes v. CommissionerUnited States Tax Court · 1997
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