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January 1, 1988, to June 30, 1988
(Cite 90 T.C.)
MARY T. PITTMAN
U.S. GOVERNMENT PRINTING OFFICE
For sale by the Superintendent of Documents, U.S. Government Printing Office,
Washington, D.C. 20402
89 T.C. at 726 Estate of Egger v. Commissioner):
This opinion was filed September 30, 1987, not on September 23, as shown.
Counsel listing for the respondent should read:
Vincent J. Guiliano, Kevin C. Reilly, and Louis B. Jack, for the respondent.
89 T.C. at 837 and 848 (Segel v. Commissioner):
By Court order dated August 1, 1988, the text in footnote 26 on page 837 was deleted and the following text inserted in lieu thereof:
26 All ITC's generated through the 1975 tax year were used by petitioners to reduce their taxes. No ITC carryforwards remained available for petitioners through 1975—the latest year in issue for which respondent determined a minimum tax liability.
On page 848, the following paragraph was substituted for the last full paragraph:
In conclusion, we have found that sections 111, 58(h), and 47 do not provide petitioners with any statutory relief from the full recapture of the ITC's. In that tax credits are a matter of legislative grace (Rickard v. Commissioner, 88 T.C. 196), and we have not been shown any authority for granting to petitioners relief from full recapture under section 47, we hold that petitioners are liable for the full amount of ITC recapture and may not decrease their minimum tax liability on account of ITC's recaptured.
STEPHEN J. SWIFT ARTHUR L. NIMS III2
JULIAN I. JACOBS EDNA G. PARKER
JOEL GERBER MEADE WHITAKER
LAWRENCE A. WRIGHT JULES G. KÖRNER III
CAROLYN MILLER PARR PERRY SHIELDS
B. JOHN WILLIAMS, JR. LAPSLEY W. HAMBLEN, JR. THOMAS B. WELLS MARY ANN COHEN
ROBERT P. RUWE CHARLES E. CLAPP II
LAURENCE J. WHALEN
Senior judges recalled to perform judicial duties under the provisions of section 7447 of the Internal Revenue Code of 1954:
C. MOXLEY FEATHERSTON
Special Trial Judges
JOAN SEITZ PATE
HU S. VANDERVORT DANIEL J. DINAN
D. IRVIN COUVILLION JOHN J. PAJAK
NORMAN H. WOLFE LEE M. GALLOWAY
STANLEY J. GOLDBERG HELEN A. BUCKLEY
CARLETON D. POWELL PETER J. PANUTHOS
LARRY L. NAMEROFF
CHARLES S. CASAZZA, Clerk
Chief Judge Sterrett resigned May 31, 1988.
UNITED STATES TAX COURT
WASHINGTON, D.C. 20217
GENERAL ORDER NO. 2
The names of Judge Robert P. Ruwe and Judge Laurence J. Whalen are added to the list of alternate designees to Judge Mary Ann Cohen with respect to the Small Tax Case Division of the United States Tax Court effective as of July 1, 1988. The names of Judge Meade Whitaker and Judge B. John Williams, Jr., are deleted from said list effective as of that same date.
ARTHUR L. NIMS III
Dated: Washington, D.C.
June 28, 1988
TABLE OF CASES REPORTED
103 1207 116 802 649 908 558
1090 878 259 816
Abeles, Harold A. and Barbara.
et al ....
465 465 280 953 862 1000 832 908 110 862 862 505
68 656 488 1124 975 372 1154 206 862 845 237 206 237 960 171