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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.
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