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HOLDEN v. COMMISSIONER

Docket No. 21102-89.

98 T.C. 160 (1992)

LEONARD J. AND SADIE HOLDEN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 10, 1992.

Attorney(s) appearing for the Case

Charles J. Escher, for petitioners.

Michael A. Urban, for respondent.

OPINION

NIMS, Chief Judge:

Respondent determined a deficiency in petitioners' Federal income tax for 1980 in the amount of $706,133. The sole issue for decision is whether petitioners must recompute their alternative minimum tax (AMT) to take into account a net operating loss (NOL) carryback to the year at issue. All section references are to the Internal Revenue Code in effect for the year at issue. All Rule references are to the Tax Court Rules...

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