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In Charles Schwab Corp. & Includable Subs. v. Commissioner,
107 T.C. 282 (1996) (Schwab I), affd. on another issue 161 F.3d
1231 (9th Cir. 1998), cert. denied 528 U.S. 822 (1999),
petitioner claimed that the $932,979 originally deducted on its
1989 calendar year return was deductible for its short year ended
December 31, 1988. This Court held that petitioner was entitled
to deduct the $932,979 for its short year ended December 31,
1988. Id. That holding left petitioner unable to deduct the
$932,979 for its calendar year 1989, as it had on its original
1989 corporate return. For purposes of this Federal tax
litigation, petitioner now claims to be entitled to deduct
California franchise tax liabilities for the same taxable period
for which the franchise tax was calculated; i.e., the year prior
to the year for which petitioner originally deducted the
California franchise tax on its Federal tax returns. The
following schedule reflects the years and amounts for which
petitioner originally claimed California franchise tax
deductions, and the years and amounts for which petitioner claims
deductions for purposes of this litigation:
Amounts
Taxable Year Originally Claimed Now Claimed
1989 $932,979 $1,806,588
1990 1,806,588 2,066,547
1991 2,066,547 3,778,547
1992 3,778,547 5,578,718
1993 5,578,718 N/A
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