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METRO ONE TELECOMMUNICATIONS, INC. v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 12651-07.

135 T.C. 573 (2010)

METRO ONE TELECOMMUNICATIONS, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed December 15, 2010.

Attorney(s) appearing for the Case

Neil D. Kimmelfield , Lewis M. Horowitz , and John H. Gadon , for petitioner.

John D. Davis , for respondent.

OPINION

PARIS, Judge:

Petitioner petitioned the Court to redetermine respondent's determination of a $630,159 deficiency in its 2002 Federal income tax. We decide whether section 56(d)(1)(A)(i)(II) precludes petitioner from deducting an alternative tax net operating loss (ATNOL) that offsets all of petitioner's alternative minimum taxable income (AMTI).1 Our decision turns on whether petitioner's carryback of an ATNOL...

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