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Specified
Separate Liability Loss
Member Taxable Income Deductions
Lynchburg Foundry Co. $3,940,085 $1,126,467
Intermet Corp. 1,879,425 71,643
Columbus Foundries, Inc. 6,720,377 30,045
Commercial & Precision
Machining, Inc. (3,123,021) 49,818
In the notice of deficiency, issued on March 14, 1997,
respondent disallowed the group's claimed carryback, except to
the extent of $49,818, which was the amount of the specified
liability loss deductions reported by Commercial & Precision
Machining, Inc. Petitioner conceded the group's claimed
carryback to the extent of $208,949.77, and the parties have
stipulated that the remainder of the carryback, $1,019,205.23, is
attributable solely to specified liability loss deductions
claimed by Lynchburg during 1992.
The disallowed specified liability losses in issue consist
of the following amounts paid by Lynchburg, during 1992, for
State tax deficiencies, interest on those deficiencies, and
interest on a Federal income tax deficiency:
Disallowed Specified Liability Losses Amount
State tax deficiencies $717,617.00
Interest on State tax liabilities 299,412.63
Interest on a Federal income tax deficiency 2,175.60
The aforementioned State taxes and interest arose out of the
State of Michigan's audit of Lynchburg's 1986, 1987, and 1988
Michigan Single Business Tax returns. During 1992, Lynchburg
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