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J. A. TOBIN CONSTRUCTION CO. v. COMMISSIONER

Docket No. 10063-82.

85 T.C. 1005 (1985)

J. A. TOBIN CONSTRUCTION COMPANY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 18, 1985.

Attorney(s) appearing for the Case

Richard S. Managhan and Ernest M. Fleischer, for the petitioner.

Alan V. Jacobson, for the respondent.

SWIFT, Judge:

Respondent determined a deficiency in petitioner's Federal income tax liability for the year 1975 in the amount of $306,958.67. The parties have reached a partial settlement and the remaining issues for the Court to decide concern the loss carryback and loss carryforward rules of the consolidated return regulations and the validity of certain adjustments made under section 4821 for imputed interest income.

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