- 58 - issue. Specifically, in its income tax returns for the years at issue, Radcliffe claimed the following deductions for interest paid to Bangkok Bank LA branch: Year Amount 1984 $73,791 1985 194,289 1986 211,719 In its income tax returns for the years at issue, Radcliffe claimed the following deductions for interest paid to Union Bank: Year Amount 1984 $144,427 1985 220,171 1986 120,008 In its income tax returns for the years at issue, BOT claimed the following deductions for interest paid to Union Bank: Year Amount 1984 $167,448 1985 233,853 1986 119,260 OPINION In determining that petitioner is liable for the deficien- cies in, additions to, and penalties on withholding tax that she determined with respect to Radcliffe and BOT, respondent relies on the transferee liability provisions of section 6901. Peti- tioner does not dispute that he would be liable as a transferee of each of those taxpayers under section 6901 for those deficien- cies in, additions to, and penalties on tax in the event thePage: Previous 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 Next
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