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APPENDIX
TAX COURT DOCKET NO. 5931-83
MOTION TO REDETERMINE INTEREST ON DEFICIENCY
TAX LIABILITY
TAX YEAR 1977
Petitioner's
Sec 7481(c)
Interest Nov., 1994
Computation Stipulation Difference
Determination of Overassessment for Restricted Interest
Tax liability without credit carrybacks 24,200,118 24,200,118 0
Tax assessed and paid 14,234,576 14,234,576 0
Deficiency without allowance for carrybacks 9,965,542 9,965,542 0
Tax liability after consideration of carryback from 1979 to 1977:
Foreign tax credit carryback 2,307,548 2,307,548 0
Investment tax credit carryback 7,947,605 0 7,947,605
Total credit carryback from 1979 to 1977 10,255,153 2,307,548 7,947,605
Unexplained difference included in stipulation 8,174 (8,174)
Tax liability after consideration of carryback from 1979 to 1977 13,944,965 21,900,744 (7,955,779)
Tax assessed and paid:
Total payments 14,234,576 14,234,576 0
Tentative allowance from 1979 to 1977 4,067,608 4,067,608 0
Net payments 10,166,968 10,166,968 0
Deficiency after consideration of credit carryback from 1979 to 1977 3,777,997 11,733,776 (7,955,779)
Tax liability after consideration of carryback from 1982 to 1977:
Current year investment tax credit (freed up) (4,576,641) (4,576,641) 0
Unexplained difference included in stipulation (8,174) 8,174
Foreign tax credit carryback 25,048,494 25,048,494 0
Investment tax credit carryback/(freed up) (7,947,605) 0 (7,947,605)
Work incentive tax credit carryback 15,550 15,550 0
Jobs tax credit carryback 327,269 327,269 0
Total credit carryback from 1982 to 1977 17,443,708 25,391,313 (7,947,605)
Tax liability after consideration of carryback from 1982 to 1977 1,077,898 1,077,898 0
Net payments 10,166,968 10,166,968 0
Overpayment after consideration of credit carryback from 1982 to 1977 (9,089,070) (9,089,070) 0
Determination of Overassessment
Tax liability
Tax liability without credit carrybacks 24,200,118 24,200,118 0
Current year investment tax credit (freed up) (4,576,641) (4,576,641) 0
Foreign tax credit carryback 27,356,042 27,356,042 0
Investment tax credit carryback/(freed up) 0 0 0
Work incentive tax credit carryback 15,550 15,550 0
Jobs tax credit carryback 327,269 327,269 0
Total credit carryback 27,698,861 27,698,861 0
Tax liability after consideration of credit carryback from 1979 and 1982 1,077,898 1,077,898 0
Tax assessed and paid
Total payments 14,234,576 14,234,576 0
Tentative allowance from 1979 to 1977 4,067,608 4,067,608 0
Net payments 10,166,968 10,166,968 0
Overpayment after consideration of credit carryback from 1979 and
1982, as reflected in the Tax Court Decision dated November 17, 1994 (9,089,070) (9,089,070) 0
TAX COURT DOCKET NO. 5931-83
MOTION TO REDETERMINE INTEREST ON DEFICIENCY
TAX LIABILITY
TAX YEAR 1978
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