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superseded 76 F.3d 976 (9th Cir. 1996).
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