Legal Opinion

Albertson's, Inc. v. Commissioner

United States Tax Court

Decided March 21, 1990No. Docket No. 10439-87UnpublishedCited by 2 opinions

In 1985 petitioner obtained certifications from state agencies that certain of its employees hired prior to 1983 were eligible for welfare assistance prior to employment or were hired pursuant to a work incentive program.

Read the full summary

In 1985 petitioner obtained certifications from state agencies that certain of its employees hired prior to 1983 were eligible for welfare assistance prior to employment or were hired pursuant to a work incentive program. Petitioner claimed WIN credits with respect to these employees under sections 40, SOA, and 50B, I.R.C. 1954, for its fiscal year beginning after 1982. Held, the parties' stipulation as to the interpretation of the Code sections at issue is ineffective to bind the Court as it is a stipulation as to a question of law. Held further, petitioner does not satisfy the certification…

1Opinion of the Court

ALBERTSON'S, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Albertson's, Inc. v. Commissioner

Docket No. 10439-87

United States Tax Court

T.C. Memo 1990-153; 1990 Tax Ct. Memo LEXIS 177; 59 T.C.M. (CCH) 186; T.C.M. (RIA) 90153;

March 21, 1990

In 1985 petitioner obtained certifications from state agencies that certain of its employees hired prior to 1983 were eligible for welfare assistance prior to employment or were hired pursuant to a work incentive program. Petitioner claimed WIN credits with respect to these employees under sections 40, SOA, and 50B, I.R.C. 1954, for its…

2Cases cited2 opinions

  1. Swift & Co. v. Hocking Valley Railway Co.Supreme Court of the United States · 1917
  2. Lewis v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1931

3Cited by2 opinions

  1. Albertson's, Inc., Petitioner-Appellant-Cross-Appellee v. Commissioner of Internal Revenue, Respondent-Appellee-Cross-AppellantCourt of Appeals for the Ninth Circuit · 1993
  2. Southland Corp. v. United StatesUnited States Court of Federal Claims · 1995

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API