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Corp. v. United States, ___ F.3d ___ (Fed. Cir. 1997), and cases
discussed therein.
We are obliged to apply the law as written. Because section
6404(e) does not grant authority to the Commissioner to abate
interest accruing on deficiencies for tax years beginning before
January 1, 1979, we decline to graft on to the provision an
exception for interest assessed as the result of the disallowance
of the carryback of net operating losses to the 1978 taxable
year. Consequently, we shall grant respondent's Motion for
Partial Summary Judgment.
To reflect the foregoing,
An order will be issued
denying respondent's Motion to
Dismiss for Lack of Jurisdiction
and granting respondent's Motion
for Partial Summary Judgment.
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