NIELSEN v. COMMISSIONER

Docket No. 23401-85.

87 T.C. 779 (1986)

MELVIN C. AND GWEN NIELSEN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 6, 1986.


Attorney(s) appearing for the Case

David R. Brennan, for the petitioners.

Jack Forsberg, for the respondent.


OPINION

COHEN, Judge:

This case is before the Court on petitioners' motion for partial summary judgment. The issue presented is whether section 66591 is applicable to underpayments for taxable years for which returns were filed prior to January 1, 1982, where such underpayments result from disallowance of carrybacks from taxable years for which returns were filed after December 31, 1981.

The material facts respecting...

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