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Home / Opinions / 00-157 United Dominion Industries, Inc. v. United States

00-157 United Dominion Industries, Inc. v. United States

"The case for the single-entity approach to calculating an affiliated group's PLL is straightforward. Section 172(j)(1) defines a taxpayer's 'product liability loss' for a given tax year as the lesser of its 'net operating loss for such year' and its product liability 'expenses.' In order to apply this definition, the taxpayer first determines whether it ...

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