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Because petitioner under section 441 elected a "52-53 week"
taxable year, petitioner's consolidated corporate Federal income
tax returns for each of 1990 through 1994 accurately reflected
petitioner's taxable years beginning and ending on different
dates in late June and July (i.e., on the Sunday nearest the last
day of June of each year).
However, as set forth below, on the protest letter that
petitioner mailed to respondent, on the petition that petitioner
mailed to the Court, and on the 30-day letters and on the notice
of deficiency that respondent mailed to petitioner, the dates for
the ending of petitioner's 1990 through 1994 taxable years were
indicated as June 30 of each year. The actual last day of each
of petitioner's taxable years as reflected on petitioner's tax
returns for each year is also set forth in the schedule below:
Yearend Date Indicated On Petitioner'sRespondent's
Taxable Tax Protest 30-Day Notice Of
Year Return Letter Petition Letter Deficiency
1990 July 1 June 30 June 30 June 30 June 30
1991 June 30 June 30 June 30 June 30 June 30
1992 June 28 June 30 June 30 June 30 June 30
1993 June 27 June 30 June 30 June 30 June 30
1994 July 3 June 30 June 30 June 30 June 30
On audit of petitioner's 1992 taxable year, respondent
disallowed petitioner's $3,751,930 claimed bad debt deduction and
the related claimed NOL carryback and carryforwards to 1990,
1991, 1993, and 1994. On September 12, 1997, with the trial
herein scheduled for October 27, 1997, petitioner, in a motion to
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