- 2 - Lawrence H. Jacobson, David C. Jensen, and Michael L. Brody, for petitioner. Elsie Hall, Reid M. Huey, and Monique I.E. van Herksen, for respondent. RUWE, Judge: Respondent determined deficiencies in petitioner's Federal income taxes as follows: Year Deficiency 1982 $3,785,250 1983 3,785,250 1984 3,785,250 1985 3,785,250 The sole issue for decision is whether petitioner was required, pursuant to section 1441,1 to withhold tax on amounts of interest paid to nonresident aliens. If the answer is yes, petitioner is liable for the tax pursuant to section 1461.2 1Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. 2In Northern Ind. Pub. Serv. Co. v. Commissioner, 101 T.C. 294 (1993), we denied petitioner's motion for partial summary judgment and held that the special 6-year period of limitations contained in sec. 6501(e)(1) applies where the income subject to withholding tax under sec. 1441 is understated by an amount in excess of 25 percent of the amount of gross income stated on Form 1042.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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