- 37 - commodities contract with LTV, the shares in Olga Coal, and the debt owed to petitioner by Olga Coal were not worthless as petitioner claimed on its 1986 return. On the basis of the foregoing determinations, respondent determined that petitioner did not sustain a CNOL in 1986 as claimed on its 1986 return. Accordingly, respondent disallowed the carrybacks to 1981 and 1984 and issued a notice of deficiency to recover the tentative refunds. Respondent’s treatment of petitioner as the continuing common parent of the affiliated group and disallowance of the claimed CNOL were “determinations” under section 6212(a) in the same sense that respondent’s disallowance of the various credit carrybacks, trade or business expenses, and charitable contributions for 1974-78, 1980-81, and 1983-84 were determinations. See supra pp. 14-15. Thus, the Court was vested with jurisdiction when petitioner filed the timely petition, and our jurisdiction has not been adversely affected by the subsequent litigation in Interlake Corp. v. Commissioner, 112 T.C. 103 (1999), and the bankruptcy proceeding. Once we have jurisdiction, it remains unimpaired until we decide the controversy. GAF Corp. v. Commissioner, 114 T.C. 519 (2000). We hold we have jurisdiction to enter a decision based on the stipulation of settled issues.Page: Previous 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 Next
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