Textron Inc. and Subsidiary Companies - Page 2




                                        - 2 -                                         
                                       OPINION                                        
               LARO, Judge:  This case is before the Court fully                      
          stipulated.  See Rule 122.  Petitioner petitioned the Court to              
          redetermine respondent’s determination of deficiencies in Federal           
          income tax for its taxable years ended January 2, 1988, December            
          31, 1988, December 30, 1989, December 29, 1990, December 28,                
          1991, and January 2, 1993, in the amounts of $5,083,201,                    
          $1,783,938, $244,211, $1,152,171, $14,011,513, and $68,811,                 
          respectively.                                                               
               We decide herein whether petitioner is entitled to a claimed           
          $14,934,745 capital loss for the taxable year ended January 2,              
          1988 (1987 taxable year).1  We hold it is not.  Unless otherwise            
          indicated, section references are to the Internal Revenue Code              
          and the regulations thereunder in effect for the years in issue.2           
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.  Dollar amounts are rounded to the nearest dollar.               








               1 This case involves several issues, some of which have been           
          settled.  The other issues remaining for decision will be                   
          addressed in one or more subsequent opinions and/or orders.                 
               2 The applicable regulations were revised in 1995, with                
          prospective effect.  See T.D. 8597, 60 Fed. Reg. 36671 (July 18,            
          1995), generally effective for transactions in years beginning              
          after July 11, 1995.                                                        




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