- 30 -- 30 - 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 1978Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
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