Turner Broadcasting System, Inc. and Subsidiaries - Page 3

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               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.                                                                  




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