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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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