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Eric R. Fox, Hamish P.M. Hume, and Clifton B. Cates III, for
petitioner.
Wilton A. Baker, Alfred C. Bishop, Jr., Steven J. Hankin,
Richard Osborne, and Teri A. Culberton, for respondent.
WELLS, Judge: Respondent determined a deficiency in
petitioner Intermet Corporation's (Intermet) Federal income tax
in the amount of $615,019 for 1984. The deficiency arose out of
respondent's disallowance of Intermet's specified liability loss
carryback from 1992 to 1984. After concessions by petitioner,
the issues to be decided are: (1) Whether, for purposes of the
10-year carryback provided in section 172(b)(1)(C), certain
expenditures incurred by Lynchburg Foundry Co. (Lynchburg), a
member of the Intermet consolidated group, qualify as "specified
liability loss" within the meaning of section 172(f), and, if so,
(2) to what extent the specified liability losses may be carried
back by the consolidated group. Unless otherwise indicated, all
section references are to the Internal Revenue Code in effect for
the year in issue.
FINDINGS OF FACT
The parties submitted the instant case on the basis of fully
stipulated facts and certain stipulated exhibits. The parties'
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