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1987, 1988, and 1989.
C. Issues With Respect to Holdings
1. Whether income should be allocated to Holdings pursuant
to section 482 for its taxable years ended June 30, 1987, 1988,
and 1989;
2. whether Holdings is entitled to claimed deductions for
legal and audit fees for its taxable year ended June 30, 1987;
3. whether Holdings is entitled to claimed deductions for
professional and legal fees for its taxable years ended June 30,
1988 and 1989;
4. whether Holdings is entitled to claimed deductions for
employee training and recruiting for its taxable year ended June
30, 1989;
5. whether Holdings is liable for environmental tax
pursuant to section 59A for its taxable year ended June 30, 1989;
6. whether Holdings is liable for additions to corporate
income tax pursuant to sections 6653(a) and 6661 for its taxable
years ended June 30, 1987, 1988, and 1989.
II. FINDINGS OF FACT
Some of the facts have been stipulated for trial pursuant to
Rule 91. The parties’ stipulations of facts are incorporated
herein by reference, and they are found accordingly.
A. Petitioners
LTD, an investment management and financial services
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