Legal Opinion

Craigie, Inc. v. Commissioner

United States Tax Court

Decided March 19, 1985No. Docket No. 21240-80Published

For the taxable years 1971 through July 24, 1975, petitioner was a member of an affiliated group of corporations filing consolidated returns. On the consolidated return for 1973, Fidelity the common parent, claimed a deduction of $ 22,172,534 for an investment loss. On examination of the return, respondent disallowed the claimed loss as a deduction for 1973 and issued a notice of deficiency.

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For the taxable years 1971 through July 24, 1975, petitioner was a member of an affiliated group of corporations filing consolidated returns. On the consolidated return for 1973, Fidelity the common parent, claimed a deduction of $ 22,172,534 for an investment loss. On examination of the return, respondent disallowed the claimed loss as a deduction for 1973 and issued a notice of deficiency. By signing a statutory notice statement-waiver (Form 4089) on Mar. 26, 1980, Fidelity agreed that the loss was not deductible for 1973. Petitioner did not sign or agree to the execution of the waiver. For…

1Opinion of the Court

Craigie, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent

Craigie, Inc. v. Commissioner

Docket No. 21240-80

United States Tax Court

84 T.C. 466; 1985 U.S. Tax Ct. LEXIS 104; 84 T.C. No. 34;

March 19, 1985. March 19, 1985, Filed

For the taxable years 1971 through July 24, 1975, petitioner was a member of an affiliated group of corporations filing consolidated returns. On the consolidated return for 1973, Fidelity the common parent, claimed a deduction of $ 22,172,534 for an investment loss. On examination of the return, respondent disallowed the claimed loss as a deduction for 1973…

2Cases cited10 opinions

  1. Jacklin v. CommissionerUnited States Tax Court · 1982
  2. Charles Ilfeld Co. v. HernandezSupreme Court of the United States · 1934
  3. Shiosaki v. CommissionerUnited States Tax Court · 1974
  4. Georgia-Pacific Corp. v. CommissionerUnited States Tax Court · 1975
  5. Union Electric Company of Missouri v. The United StatesUnited States Court of Claims · 1962

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