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1 50 percent of the interest due on the deficiency.
Respondent determined deficiencies in and additions to LTD's
Federal income taxes as follows:2
InverWorld, Ltd., Docket No. 3444-93
Additions to Tax
Tax Year Sec. Sec. Sec. Sec.
Sec.
Ended Deficiency 6651(a)(1) 6653(a)(1)(A) 6653(a)(1)(B) 6655
6656
June 30, 1987 $2,060,490 $515,123 $103,025 1 $101,169 $206,049
June 30, 1988 2,299,853 574,963 114,993 1 128,503 229,985
2
Respondent sent LTD a notice of liability for withholding
tax and a notice of deficiency in corporate income tax, each
dated Sept. 7, 1990, for its taxable years ended 1984, 1985, and
1986. LTD timely filed a petition with this Court contesting
respondent's determinations in the notice of liability. LTD
attached the notice of liability to its petition but did not
attach the notice of deficiency. In its petition, LTD did not
refer to or dispute any of the deficiencies in corporate income
tax determined in the notice of deficiency. Because LTD failed
to contest the determinations in the notice of deficiency,
respondent, on Feb. 6, 1991, assessed the amounts of the tax,
additions to tax, and interest for LTD's taxable years ended
1984, 1985, and 1986, as determined in the notice of deficiency.
After the period for filing a petition with respect to the
notice of deficiency had expired, LTD filed a motion for leave to
file amendments to its petition contesting the notice of
liability, pursuant to Rule 41(a). In InverWorld, Ltd. v.
Commissioner, 98 T.C. 70 (1992), affd. 979 F.2d 868 (D.C. Cir.
1992), we held, inter alia, that, because each notice must be
considered independently for purposes of jurisdiction, this Court
did not acquire jurisdiction over the corporate income tax
deficiencies determined in the notice of deficiency by virtue of
a petition which contested only the withholding tax
determinations in the notice of liability.
Respondent then assessed and collected $7.7 million of LTD's
corporate income tax deficiencies and additions to tax. In the
U.S. District Court for the District of Columbia, LTD has
commenced a refund action, InverWorld, Ltd. v. United States,
Civil Action No. 93-1704-LFO (D.D.C., filed Mar. 11, 1994), which
has been stayed pending resolution of the instant case.
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