United States Ninth Circuit
Metro One Telecommunications, Inc. v. Comm'r of Internal Revenue, 11-70819
The judgment of the Tax Court that petitioner was not entitled to tax relief under section 56 of the Internal Revenue Code (Relief Rule), which permitted taxpayers subject to the Alternative Minimum Tax to offset up to 100% of their taxable income with net operating losses, is affirmed where because the term "carryovers" as used in the Relief Rule means net operating losses that are carried forward from a tax year to a later tax year, petitioner cannot use net operating losses that are carried back to 2001 or 2002 from a later tax year to take advantage of the Relief Rule.
Appellate Information
- Decided 12/19/2012
- Published 12/19/2012
Judges
- Smith
Court
- United States Ninth Circuit