Paul A. Rendina and Janet Mae Rendina - Page 10

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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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