Thrifty Oil Co. & Subsidiaries v. Commissioner
United States Tax Court
P filed consolidated Federal income tax returns for the years at issue (TYE Sept. 30, 2000, 2001, and 2002) on which it claimed environmental remediation expense deductions. R disallowed the claimed deductions after determining that they were each the second tax deduction P had claimed for a single economic loss.
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P filed consolidated Federal income tax returns for the years at issue (TYE Sept. 30, 2000, 2001, and 2002) on which it claimed environmental remediation expense deductions. R disallowed the claimed deductions after determining that they were each the second tax deduction P had claimed for a single economic loss. The first deduction had been reported as a capital loss on P's Federal income tax return for TYE Sept. 30, 1996, and carried forward, with the last portion claimed on P's Federal income tax return for TYE Sept. 30, 2001. Held: P is not entitled to the environmental remediation…
1Opinion of the Court
OPINION
Wherry, Judge:
This case is before the Court on a petition for redetermination of income tax deficiencies determined by respondent for petitioner’s taxable years ended (tye) September 30, 2000, 2001, and 2002. In its simplest form, the issue is whether, given Charles Ilfeld Co. v. Hernandez, 292 U.S. 62 (1934), and its progeny, petitioner is entitled to environmental remediation expense deductions claimed for the years at issue when, economically, those same losses were claimed as capital loss deductions for years not before the Court.
Background
This case was submitted fully stipulated…
2Cases cited38 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- The Black & Decker Corporation v. United StatesCourt of Appeals for the Fourth Circuit · 2006
- United States v. Skelly Oil Co.Supreme Court of the United States · 1969
- Charles Ilfeld Co. v. HernandezSupreme Court of the United States · 1934
- Coltec Industries, Inc. v. United StatesCourt of Appeals for the Federal Circuit · 2006
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