- 2 -
Robert J. Percy, Bruce I. Judelson, Richard A. Levine,2
Mortimer M. Caplin,3 Richard E. Timbie,3 and Christopher S.
Rizek,3 for petitioners.
Stephen C. Best and Bradford A. Johnson, for respondent.
SUPPLEMENTAL MEMORANDUM OPINION
NIMS, Judge: On July 6, 2000, the Court filed its opinion
in this case, T.C. Memo. 2000-208, in which we disallowed
petitioners’ claimed foreign tax credits. We further held that
petitioners could not reserve the right, as part of a Rule 155
computation, to elect to take deductions for foreign taxes in
lieu of the disallowed foreign tax credits. This issue, raised
for the first time on brief in only the most summary fashion, had
not previously been addressed through the pleadings or at trial
and was therefore deemed untimely.
Subsequently, in August of 2000, a motion for
reconsideration and separate motions to amend were filed wherein
certain of petitioners moved for reconsideration of that portion
2 Richard A. Levine has entered an appearance as counsel for
petitioners at docket Nos. 7561-98, 7563-98, 7564-98, 7567-98,
19356-98, 19357-98, 19358-98, and 19359-98.
3 Mortimer M. Caplin, Richard E. Timbie, and Christopher S.
Rizek have each entered an appearance as counsel for petitioners
at docket Nos. 7561-98, 7563-98, 7564-98, 7565-98, 7566-98, 7567-
98, 19354-98, 19355-98, 19356-98, 19357-98, 19358-98, and 19359-
98.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011