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