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interest from being imposed on the deficiency without
reduction by a foreign tax carryback from a subsequent
year. Held, further, the interest on the deficiency
amounts eliminated by the carryback from 1981 stops
accruing as of the end of 1981, and the interest on the
deficiency amount eliminated by the carryback from 1982
stops accruing as of the due date of the 1982 return.
Cf. sec. 6611(g) (now sec. 6611(f)(2)), I.R.C. 1954,
prior to and after the Tax Equity and Fiscal
Responsibility Act of 1982, Pub. L. 97-248, sec.
346(c), 96 Stat. 637.
Joel V. Williamson, Wayne S. Kaplan, Thomas L. Kittle-Kamp,
Marjorie M. Margolies, and Robert H. Perlman, for petitioner.
Beth L. Williams and Ewan D. Purkiss, for respondent.
SUPPLEMENTAL OPINION
TANNENWALD, Judge: A decision was entered in this case on
December 9, 1993, pursuant to a stipulated computation, in
accordance with this Court's opinion, 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1995), amended and superseded 76 F.3d 976 (9th Cir. 1996). On
May 9, 1997, petitioner filed a motion under section 7481(c)1 and
Rule 261 to redetermine interest on the deficiencies for the 1979
and 1980 taxable years.
1 We refer to sec. 7481(c) of the Internal Revenue Code as in
effect at the time petitioner's motion was filed. Unless
otherwise indicated, all other section references are to the
Internal Revenue Code in effect for the taxable years in issue,
and all Rule references are to the Tax Court Rules of Practice
and Procedure.
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