Albertson's, Inc. v. Commissioner
United States Tax Court
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
- Swift & Co. v. Hocking Valley Railway Co.Supreme Court of the United States · 1917
- Lewis v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1931
3Cited by2 opinions
- Albertson's, Inc., Petitioner-Appellant-Cross-Appellee v. Commissioner of Internal Revenue, Respondent-Appellee-Cross-AppellantCourt of Appeals for the Ninth Circuit · 1993
- Southland Corp. v. United StatesUnited States Court of Federal Claims · 1995