Charles Schwab Corp. v. Comm'r
United States Tax Court
P, for Federal tax reporting purposes, claimed a California franchise tax deduction for 1989. Subsequently, P claimed the 1989 deduction for an earlier year and was successful in that claim in prior litigation before this Court.
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P, for Federal tax reporting purposes, claimed a California franchise tax deduction for 1989. Subsequently, P claimed the 1989 deduction for an earlier year and was successful in that claim in prior litigation before this Court. For purposes of these cases, P claims entitlement to franchise tax deductions for 1989 in the amount originally deducted for 1990. In like manner, P claims the franchise tax deductions originally claimed for 1993, 1992, and 1991 are now deductible for the preceding years of 1992, 1991, and 1990, respectively. R contends that sec. 461(d), I.R.C., proscribes such…
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
122 T.C. 191; 2004 U.S. Tax Ct. LEXIS 10; 122 T.C. No. 10;
March 9, 2004, Filed
Charles Schwab Corp. v. Commissioner, 161 F.3d 1231, 1998 U.S. App. LEXIS 30868 (9th Cir., 1998)
Decisions will be entered under Rule 155.
P, for Federal tax reporting purposes, claimed a California franchise tax deduction for 1989. Subsequently, P claimed the 1989 deduction for an earlier year and was successful in that claim in prior…
2Cases cited26 opinions
- United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989
- Kimbell-Diamond Milling Co. v. Comm'rUnited States Tax Court · 1950
- Kimbell-Diamond Milling Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
- Estate of Andrews v. CommissionerUnited States Tax Court · 1982
- Propstra v. United StatesCourt of Appeals for the Ninth Circuit · 1982
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