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corporation income tax of $89,455, and an addition of $22,364 for
failure to file its corporation income tax return. WSAI’s
liability for 1988 U.S. corporation income tax and the failure to
file addition remains unresolved; respondent had issued no
statutory notice of deficiency to WSAI (or to petitioner as
transferee) as of the date of issuance of this report.
OPINION
Because WSAI has never filed a 1988 U.S. corporation income
tax return, the periods of limitation on assessment of WSAI’s
1988 corporation income tax liability and petitioner’s transferee
liability remain open indefinitely. In the course of our
unsuccessful efforts to lead the parties to a comprehensive
settlement or to postpone the submission of this case in order to
allow the related corporation tax and transferee liability cases
to be perfected and consolidated with this case, we observed to
the parties that it would have been preferable, in the interests
of efficient case management and sound judicial administration,
to bring the cases on together, so that the interrelated
questions of corporate taxable income and earnings and profits,
which bear on the transferee liability and dividend questions,
could have been tried together.10 Be that as it may, we decide
9(...continued)
sale of the condominium units.
10For an example of a consolidated proceeding dealing with
(continued...)
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