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1977 and 1978 tax years, alleging that respondent has erroneously
calculated such interest. The issue for decision is whether
respondent has failed to take into account the carryback of a
1979 investment tax credit (ITC), and consequently overcharged
petitioner for interest which accrued before the effect of a 1982
net operating loss (NOL) carryback.
Background
In 1983, respondent determined deficiencies against
petitioner's predecessor in interest for the tax years 1975
through 1979. Petitioner's predecessor challenged these
deficiencies in this Court, which issued the following five
opinions, under this same docket number, each captioned
Continental Illinois Corp. v. Commissioner: T.C. Memo. 1988-318,
T.C. Memo. 1989-468, T.C. Memo. 1989-636, 94 T.C. 165 (1990), and
T.C. Memo. 1991-66. Decision was entered on May 13, 1992 (the
1992 decision), and was based on Rule 155 computations (the 1992
computations) which took into account certain amounts of an ITC
carried back from 1979.
Portions of this Court's decision as reflected in T.C. Memo.
1988-318, T.C. Memo. 1989-636, and T.C. Memo. 1991-66 were
appealed by the parties to the Court of Appeals for the Seventh
Circuit. The Court of Appeals for the Seventh Circuit affirmed
in part and reversed in part and remanded the case to this Court
in Continental Illinois Corp. v. Commissioner, 998 F.2d 513,
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