The Charles Schwab Corporation and Subsidiaries v. Commissioner

123 T.C. No. 18

UNITED STATES TAX COURT THE CHARLES SCHWAB CORPORATION AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent* Docket Nos. 16903-98, 18095-98. Filed September 29, 2004. In an earlier opinion, Charles Schwab Corp. & Subs. v. Commissioner,

122 T.C. 191

(2004) (Schwab II), we held that sec. 461(d), I.R.C., applied to a 1972 change in California (Cal.) franchise tax law. R contended that if sec. 461(d), I.R.C., applied, P would not be entitled to the $932,979 Cal. franchise tax deduction it had claimed for its 1989 Federal tax year. P contended that sec. 461(d),…