- 3 - Richard E. Timbie and Trevor Washington Swett III, for petitioner in docket No. 14786-96. Robert J. Shilliday, Jr., for respondent. OPINION RUWE, Judge: Respondent determined a deficiency in Tracinda Corp.'s (Tracinda) Federal income tax for the taxable year ending January 31, 1991, in the amount of $54,763,119 and an accuracy- related penalty under section 6662(d)1 in the amount of $10,952,616. Respondent determined deficiencies in Turner Broadcasting System, Inc.'s (TBS) Federal income tax for the taxable year ending December 31, 1991, in the amount of $21,538,821 and for the taxable year ending December 31, 1992, in the amount of $49,050,854. Tracinda's deficiency results from disallowance of a basis adjustment arising out of its acquisition of United Artists Corp. (UA) from MGM/UA Entertainment Co. (MGM) in 1986. TBS acquired MGM simultaneously with the sale of UA to Tracinda. The TBS deficiencies result, in part, from disallowance of net capital loss carryforward deductions originating from the 1986 sale of UA and carried forward into subsequent years. MGM's basis in UA was greater than the consideration received for all the UA shares sold. The 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 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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