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operating loss carryback from Interlake’s 1986 year to 1983, a
deduction for a net operating loss carryback from petitioner’s
1986 year to 1984, general business credit carrybacks from
Interlake’s 1986 year to 1984 and 1983; a general business
carryback from petitioner’s 1986 year to 1984, a foreign tax
credit carryback from Interlake’s 1986 tax year to 1984.
Paragraph 9 provides that all other issues raised by the
petition, including the contention in the petition “relating to
jurisdiction”, are conceded by petitioner.
Paragraph 10 provides that petitioner would be liable for
“deficiencies in income tax in the amount of $1,709,109 for the
taxable year ended December 27, 1981, and $3,109,029 for the
taxable year ended December 30, 1984," if the tentative refunds
petitioner received on November 1, 1987, “do not represent a
rebate to Interlake.”
Petitioner continued to be represented by Messrs. Newman and
Updegraft when it entered into the stipulation of settled issues.
Mr. Newman’s signature appears on the stipulation of settled
issues.
On September 28, 1998, petitioner filed a chapter 11
petition with the United States Bankruptcy Court. On January 11,
1999, the proceedings in the Tax Court were stayed pursuant to 11
U.S.C. section 362 (2002).
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