Hallmark Cards, Incorporated and Subsidiaries - Page 2

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                                       OPINION                                        
               TANNENWALD, Judge:  On January 28, 1997, the Court entered a           
          decision in the instant case, which became final within the                 
          meaning of section 7481(a)1 on April 28, 1997.  On March 26,                
          1998, petitioner timely filed a motion under section 7481(c) and            
          Rule 261 to redetermine interest on deficiency for the taxable              
          year 1987 (motion to redetermine interest).  Subsequently, on               
          August 27, 1998, petitioner filed a motion for leave to withdraw            
          motion to redetermine interest on deficiency (motion to                     
          withdraw).  Petitioner filed its motion to withdraw in order to             
          pursue remedies in another forum, citing concerns about this                
          Court's jurisdiction to redetermine interest under the facts of             
          the instant case.                                                           
               Petitioner is a corporation whose principal offices were in            
          Kansas City, Missouri, at the time its petition was filed.  The             
          Court's decision, pursuant to the stipulation of the parties,               
          determined that there were overpayments for each of the taxable             
          years 1987 and 1988.  According to the stipulation, the                     
          overpayment for 1987 was due to a foreign tax carryback from                
          1989.  The amount of the carryback exceeded the amount of the               
          deficiency (as shown in the stipulation) computed without taking            
          such foreign tax carryback into effect.  Petitioner has paid the            


               1  Unless otherwise indicated, all section references are to           
          the Internal Revenue Code as amended, and all Rule references are           
          to the Tax Court Rules of Practice and Procedure.                           




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