-7-
10, April 10, July 10, and October 10, through the term of the
agreement, the amounts of $72,200 for each of the first four
quarterly payments, $88,400 for each of the next four quarterly
payments, and $80,300 for each quarterly payment thereafter until
petitioner paid the total amount of its assessments.
Petitioner claims it made payments to the FPCF totaling
$1,014,378.94 from January 17, 1984 through May 25, 1988, with
respect to arrears in its insurance coverage between 1976 and
1981. Petitioner, however, has not provided sufficient evidence
as to the amount claimed. Moreover, even if the payments were
made in the amount asserted by petitioner, it is unclear from the
record the years to which the payments correspond. Petitioner
argues that the FPCF payments made between 1984 and 1988 under
the settlement agreement correspond to the "fourth assessment"
which covers FPCF years 1976 through 1981, years in which
petitioner was a tax-exempt organization under section 501. The
settlement agreement, however, clearly states that the payment
schedule prescribed therein covers the fifth, sixth, seventh, and
eighth assessments.
Section 501(a) exempts certain organizations, including
those described under section 501(c)(3), from taxation unless the
exemption is denied under sections 502 or 503. Section 162(a)
allows as a deduction all the ordinary and necessary expenses
paid or incurred during the taxable year in carrying on a trade
or business.
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011