3
may be carried back 10 years. This is the first case in which
we, or, to the best of our knowledge, any court, has decided the
scope of section 172(f)(1)(B). As discussed below, we hold that
petitioners’ compliance expenses at issue here are not specified
liability losses, and we deny petitioners' motion for partial
summary judgment.
A motion for summary judgment or partial summary judgment
may be granted if there is no genuine issue of material fact and
the decision can be rendered as a matter of law. Rule 121;
Shiosaki v. Commissioner, 61 T.C. 861, 862-863 (1974). The
parties agree that there is no material fact in dispute relating
to the motion. The parties have settled all of the other issues
in this case.
Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the years at issue. Rule
references are to the Tax Court Rules of Practice and Procedure.
Background
A. Petitioners
Petitioners are corporations the principal places of
business of which were in Seattle, Washington, when the petitions
were filed.
Petitioners used the accrual method of accounting and
reported their income on fiscal years ending November 30.
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