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7. whether LTD is liable for additions to withholding tax
pursuant to sections 6651, 6653(a), and 6656 for calendar years
1984 through 1989.
B. Issues With Respect to INC
1. Whether income should be allocated to INC pursuant to
section 482 for its taxable years ended June 30, 1985 and 1986;
2. whether INC is entitled to claimed deductions for legal
and audit expenses for its taxable year ended June 30, 1986;
3. whether the net operating loss deduction claimed by INC
should be increased for its taxable year ended June 30, 1985, and
decreased for taxable year ended June 30, 1986;
4. whether investment credits claimed by INC should be
increased for its taxable year ended June 30, 1985, and decreased
for its taxable year ended June 30, 1986;
5. whether INC is liable for additions to corporate income
tax pursuant to sections 6653(a) and 6661 for its taxable years
ended June 30, 1985 and 1986;
6. whether INC is liable as a withholding agent pursuant
to sections 1441 and 1442 for failing to withhold tax on items of
income of nonresident aliens and foreign corporations derived
from sources within the United States for calendar years 1987,
1988, and 1989;
7. whether INC is liable for additions to withholding tax
pursuant to sections 6651, 6653(a), and 6656 for calendar years
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