Intel Corporation and Consolidated Subsidiaries - Page 1

                                   111 T.C. No. 4                                     


                               UNITED STATES TAX COURT                                


           INTEL CORPORATION AND CONSOLIDATED SUBSIDIARIES, Petitioner v.             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent*                     


               Docket No. 23010-89.                   Filed July 30, 1998.            


                    P had deficiencies in its Federal income tax for                  
               the taxable years 1979 and 1980.  From the taxable year                
               1981, P carried back an amount of foreign tax to 1979                  
               and 1980.  From 1982, P carried back additional foreign                
               tax to 1980.  R computed interest under sec. 6601,                     
               I.R.C. 1954, from the respective due dates of the                      
               returns for 1979 and 1980 until the end of 1981 for the                
               deficiency amounts for 1979 and 1980, respectively,                    
               eliminated by the carryback from 1981.  For the                        
               deficiency amount in 1980 eliminated by the carryback                  
               from 1982, R computed interest from the due date of the                
               return for 1980 until the due date of the return for                   
               1982.  P filed a motion under sec. 7481(c), I.R.C.                     
               1986, to redetermine interest.  Held, for the years at                 
               issue, sec. 904(c), I.R.C. 1954, does not prevent                      

          *  This supplements Intel Corp. v. Commissioner, 100 T.C. 616               
          (1993), affd. 67 F.3d 1445 (9th Cir. 1995), amended and                     
          superseded 76 F.3d 976 (9th Cir. 1996).                                     




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