- 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
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