2
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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