2002 IRS Actions on Decisions Library

All Actions on Decisions for 2002 are only available in Adobe Acrobat PDF format. You will need the appropriate PDF Reader to view, print, or download the PDF version. There are different Acrobat Readers for different platforms. If you do not have the appropriate Acrobat Reader plugged into your browser, click on the link at the bottom of the page to obtain a FREE copy from Adobe. See the bottom of the page for links to AODs issued in other years.

CC-2002-06(PDF, 10K)	12/09/2002
Curell v. United States
Issue: Does an LL.M. in Taxation qualify as a “special factor” justifying an award of attorneys’ fees to plaintiff’s counsel in excess of the statutory rate under I.R.C. § 7430?
CC-2002-05(PDF, 13K)	12/09/2002
Robert L. Beck v. Commissioner
Issue: Whether the Tax Court has jurisdiction to review the Service’s determination that a spouse is not entitled to equitable relief under I.R.C. § 66(c) in a deficiency proceeding.
CC-2002-04(PDF, 7K)	03/11/2002
Paul Pekar v. Commissioner
Issue: Whether the late filing addition to tax under I.R.C. § 6651(a)(1) applies to a return received by the Internal Revenue Service after its prescribed filing date, when the return was mailed in an envelope bearing an official postmark of a foreign country showing the return had been mailed on the date it was due.
CC-2002-03(PDF, 13K)	02/19/2002
Ridge & Marjory Harlan v. Commissioner
Issue: Whether, in determining the applicability of the 6-year period of limitations provided by section 6501(e)(1)(A), second-tier partnership information returns are taken into account in computing the amount of gross income stated in the return.
CC-2002-02(PDF, 9K)	02/11/2002
Sutherland Lumber-Southwest, Inc. v. Commissioner
Issue: Whether a taxpayer that provides vacation flights to employees and includes the value of the flights in the employees’ income using the SIFL rates of Treas. Reg. § 1.61-21(g) may then deduct the full (higher) cost of providing the flights, notwithstanding the deduction disallowance provisions of I.R.C. § 274(a).
CC-2002-01(PDF, 9K)	02/11/2002
Intermet Corporation & Subs. v. Commissioner
Issue: Whether deductions for state income tax deficiencies and interest thereon as well as interest on federal income tax deficiencies, all attributable to tax liabilities arising at least three years before the beginning of the taxable year, and taken into account in computing a net operating loss, qualify for a ten-year carryback as specified liability losses under former I.R.C. § 172(f)(1)(B).
CC-2003-02(PDF, 61K)	02/04/2002
Intermet Corporation & Subs. v. Commissioner
Issue: Whether deductions for state income tax deficiencies and interest thereon as well as interest on federal income tax deficiencies, all attributable to tax liabilities arising at least three years before the beginning of the taxable year, and taken into account in computing a net operating loss, qualify for a ten-year carryback as specified liability losses under former I.R.C. § 172(f)(1)(B).

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