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 v. Commissioner, 100 T.C. 616 (1993), affd. 67 F.3d 1445 (9th Cir. 1995), amended and superseded 76 F.3d 976 (9th Cir. 1996).Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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