Arthur D. Pasternak, Douglas R. Cox, and Jeffrey A. Fiarman,
for petitioner.
Karen E. Chandler and Kristine A. Roth, for respondent.
OPINION
TANNENWALD, Judge: Respondent determined deficiencies in
Federal withholding taxes and additions to tax as follows:
Additions to Tax
Year Deficiency Sec. 6651(a)(1)1
1987 $678,449 $169,612
1988 881,067 220,267
1989 825,513 206,378
1990 641,837 160,459
The issue in dispute is whether petitioner, a corporation
organized under the laws of the Kingdom of The Netherlands, is
liable for withholding taxes on royalties paid to a Bermuda
corporation, and additions to tax for failure to file Forms 1042
for each of the years in issue.
All the facts have been stipulated. The stipulation of
facts and attached exhibits are incorporated herein by this
reference.
1 All section references are to the Internal Revenue Code in
effect for the years in issue, and Rule references are to the Tax
Court Rules of Practice and Procedure.
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