Tate & Lyle, Inc. and Subsidiaries - Page 2

                                        - 2 -                                         

          respondent's Motion for Leave to File Amendment to Answer filed             
          in each docket.                                                             
          Background                                                                  
               Tate & Lyle, Inc. (petitioner), is the common parent of a              
          consolidated group of corporations including A.E. Staley                    
          Manufacturing Co.  At the time the petitions were filed in these            
          cases, petitioner maintained its principal place of business in             
          Wilmington, Delaware.                                                       
          Docket No. 26352-93                                                         
               On September 15, 1993, respondent issued a statutory notice            
          of deficiency to petitioner (and its subsidiaries) determining a            
          deficiency of $1,718,143 in its Federal income tax for the                  
          taxable year ended September 30, 1989.  A review of the notice of           
          deficiency shows that respondent determined the deficiency after            
          making a number of adjustments to petitioner's items of income              
          and expense and after allowing petitioner certain credits,                  
          including the general business credit provided by section 38.               
          Respondent computed petitioner's general business credit on the             
          assumption that petitioner is entitled to a general business                
          credit carryover of $18,944,258 from its taxable year ended                 
          September 30, 1988.                                                         
          Petitioner invoked this Court's jurisdiction by filing a                    
          timely petition for redetermination on December 14, 1993,                   
          assigned docket No. 26352-93.  Although the petition includes an            
          allegation that respondent erred in computing the amount of                 



Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  Next

Last modified: May 25, 2011