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transition rule (supply or service transition rule) of section
204(a)(3) of the Tax Reform Act of 1986 (TRA of 1986 or the Act),
Pub. L. 99-514, 100 Stat. 2085, 2149, to determine whether
MetroVision properly claimed the ITC (transition ITC). We shall
deny both motions. Our reasons follow.
Unless 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.
I. Introduction
Approximately 186 cable franchise agreements are involved in
petitioner’s case and about 200 similar agreements are involved
in the cases consolidated with petitioner’s case. Although the
motions relate to a single cable television franchise agreement,
the issue presented is common to all of the cable franchises and
systems in dispute. Therefore, resolution of the issue in this
case will facilitate resolution of the same issue as it arises in
the other cases.
II. Background
A. Introduction
For purposes of the motions, the parties have stipulated
certain facts. We accept the stipulated facts as being true for
purposes of deciding the motions. The stipulation of facts, with
attached documents, is incorporated herein by this reference.
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