For Tax Professionals  

2003 IRS Actions on Decisions Library

All Actions on Decisions for 2003 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.

General Electric Co. & Subs. v. Commissioner
Issue: Whether aircraft engines and thrust reversers sold by the taxpayer through its wholly-owned domestic international sales corporation (DISC) to airframe manufacturers for incorporation in the United States into aircraft that are delivered for use outside the United States constitute "export property" within the meaning of � 993(c)(1)(B) of the Internal Revenue Code and Treasury Reg. 1.993-3(d)(2)(iii).
Michael and Nancy B. McNamara v. Commissioner
Issue: Whether farm rental income is includible in self-employment income if the lessor materially participates in farm production, but the lease agreement itself does not require the lessor to materially participate.
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 carry-back as specified liability losses under former Internal Revenue Code � 172(f)(1)(B).
Doyle, Dane, Bernbach, Inc. v. Commissioner
Issue: Whether an accrual method taxpayer must include in its gross income for 1975 amounts representing claimed refunds of New York State franchise taxes and New York City general corporate taxes paid for 1972 which became refundable by virtue of a net operating loss incurred in 1975 and carried back to 1972.


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