- 9 -
years 1984 and 1985 which took into account the earlier tentative
refund allowance paid to petitioner. On the revised Form 1139,
Acme and its consolidated subsidiary requested tentative refunds
of income tax for 1984 and 1985 in the amounts of $3,109,026 and
$3,524,388, respectively.
On or about November 1, 1987, the service center, after
processing Acme's revised Form 1139 relating to 1984 and 1985 and
the original Form 1139 relating to 1981, made tentative refund
allowances (tentative refunds) to Acme as follows:
Amount of
Tentative Refund Taxable Year
Allowance Ended
$148,692 12/27/81
3,109,026 12/30/84
3,524,388 12/29/85
The service center charged the tentative refund allowances
that it paid to Acme to the Federal income tax account of the
group for 1984 (i.e., to the tax account of Acme). Neither
petitioner nor the group received, directly or indirectly, any
portion of the tentative refunds paid to Acme.
Examination of Acme's 1986 Tax Return
A subsequent examination of Acme's 1986 short-year Federal
income tax return resulted in a determination by the Internal
Revenue Service (Service) that Acme and its consolidated
subsidiary did not sustain a CNOL in the amount of $29,286,968,
as claimed on their 1986 consolidated Federal income tax return.
Instead, the Service determined that Acme and its consolidated
subsidiary have a CNOL in the amount of $13,180,810 for the 1986
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011