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net operating loss carryback from 1983 to 1980, a consolidated
investment credit carryover from 1979 to 1980, and consolidated
investment, jobs, qualified research, and energy credit
carrybacks from 1983 to 1980. For 1981, respondent determined a
deficiency resulting from the disallowance of consolidated net
operating loss carrybacks from 1982, consolidated qualified
research credit carrybacks from 1984, consolidated investment
credit carrybacks from 1982 and 1983, and consolidated general
business credit carrybacks from 1984. Respondent made several
determinations for 1983, including disallowing a claimed section
162 expense, ordinary losses realized on the liquidation and
dissolution of Erie Mining Company, a subsidiary, disallowing a
consolidated net operating loss carryback from Interlake’s 1986
tax year, and disallowing other carrybacks and carryovers. With
respect to 1984, respondent disallowed a trade or business
expense, charitable contributions, the net operating loss carried
back from 1986, and disallowed other credits and carrybacks.
On May 16, 1994, petitioner filed a petition in which it
disputed all of respondent’s determinations. Paragraph 5v of the
petition alleges that respondent “erroneously determined that
* * * [petitioner] is the common parent of the affiliated group”.
Additionally, the petition alleges that the notice of deficiency
issued to petitioner was not issued to the appropriate
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