Alondra Industries, Limited, d.b.a. Accent Insulation Company and Subsidiaries, et al. - Page 2

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          Federal corporation income tax of petitioner Alondra Industries,            
          Limited, d.b.a. Accent Insulation Company (Alondra), for its                
          fiscal year ended June 30, 1987 (Alondra's fiscal 1987), and of             
          petitioner Edco Leasing Corporation (Edco) for its fiscal year              
          ended September 30, 1987 (Edco's fiscal 1987).  By notice of                
          final partnership administrative adjustment (FPAA) dated July 13,           
          1992, respondent increased the income reported on the U.S.                  
          Partnership Return of Income of petitioner Pertinax, Limited                
          (Pertinax), a partnership whose partners include Alondra and                
          Edco, for the calendar year 1987.  The deficiencies, additions,             
          and adjustment in dispute are as follows:                                   


      ket No. 10849-91 (Alondra)                                                      
      Fiscal                            Additions to tax                              
      Year  Deficiency     Sec. 6653(a)(1)(A) Sec. 6653(a)(1)(B) Sec. 6661(a)         
      1987   $836,238           $41,812       50% of the           $209,060           
      interest due                                                                    
      on $836,238                                                                     
      Docket No. 10851-91 (Edco)                                                      
      Fiscal                             Additions to tax                             
      Year  Deficiency     Sec. 6653(a)(1)(A) Sec. 6653(a)(1)(B)                      
      1987    $21,814             $1,091      50% of the                              
      interest due                                                                    
      on $21,814                                                                      
      Docket No. 24777-92 (Pertinax)                                                  
      Calendar                                                                        
      Year                            Adjustment to Income                            
      1987                                 $860,425                                   
               Petitioners' cases were consolidated for trial, briefing,              
          and opinion.                                                                




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