- 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
Last modified: May 25, 2011