Tax Court Upholds Farmer’s Current Year Deduction for Packing Materials Used in Subsequent Year

Agro-Jal Farming Enterprises, Inc. is a family owned farming corporation that produces strawberries and vegetables (the “Taxpayer”).  The Taxpayer deducted the amounts paid for the packing materials in the year they were purchased even though they were not used until the following year.  The IRS claimed that the Taxpayer was […] Read more »

Tax Court Upholds IRS Allocation of NOL Among Members of Consolidated Group

Four members of Marvel Entertainment Consolidated Group had Cancellation of Indebtedness (“COD”) income totaling $171,000,000 under IRC Section 108.  The Taxpayer took the separate entity approach in reducing the group’s net operating loss carryforward by the amount of COD income.  The Taxpayer first allocated to the four members their share […] Read more »