- 10 - 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...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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