SDI Netherlands B.V., f.k.a. SDI International B.V. - Page 2

                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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