- 59 -
TYE June 30 Gross Receipts Direct Costs
1985 $49,297 - 0 -
1986 20,735 - 0 -
1987 124,943 - 0 -
1988 83,442 - 0 -
1989 108,250 96,692
1 We have deducted from the amount of gross receipts,
$55,961, the amount of $24,152, which represents LTD's letters of
credit fees, and which has been recategorized under "Fees for
Letters of Credit" for taxable year ended June 30, 1987.
Additionally, we have deducted from the amount of gross receipts
the amount of $6,866, which represents LTD's wire and check fees,
and which has been recategorized under "Wire and Check Fees" for
taxable year ended June 30, 1987.
M. Amounts Subject to Withholding Tax
The total amounts in docket No. 27090-90 on which LTD is
potentially liable for withholding tax for each calendar year are
as follows:9 $481,692 for 1984; $1,168,498 for 1985; and
$1,135,757 for 1986. The breakdown of these amounts for each
calendar year is as follows:
Calendar Type of Interest
Year or Dividend Amount
1984 IFF $333,137
9
For calendar years 1984, 1985, and 1986, the parties
stipulated as revisions to the statutory notice of liability
amounts in docket No. 27090-90 on which LTD is potentially liable
for withholding tax. The parties, however, did not stipulate a
breakdown of the withholding amounts, which is necessary to our
analysis, infra pp. 160-184, relating to LTD’s withholding tax
liability. We note that a stipulated joint exhibit provides the
breakdown of the withholding amounts, which we set forth herein
and utilize in our analysis, infra pp. 160-184. We note that the
stipulated joint exhibit provides total amounts subject to
withholding tax different from the total amounts stipulated by
the parties.
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