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LIBERTY GLOBAL, INC. v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 341-21.

161 T.C. No. 10

LIBERTY GLOBAL, INC., Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed November 8, 2023.

Attorney(s) appearing for the Case

Rajiv Madan and Nathan P. Wacker, for petitioner.

Matthew J. Avon and Timothy L. Smith, for respondent.

OPINION

This deficiency case calls on us to confront an issue of first impression regarding the scope of section 904(f)(3).1 As relevant here, that provision governs the recapture2 of an overall foreign loss (OFL) (a concept we discuss in detail below in Discussion...

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