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Petitioner's
Sec 7481(c)
Interest Nov., 1994
Computation Stipulation Difference
Determination of Deficiency to be Paid for Restricted Interest
Tax liability without credit carrybacks 6,608,807 6,608,807 0
Tax assessed and paid 3,633,741 3,633,741 0
Deficiency without allowance for carrybacks 2,975,066 2,975,066 0
Tax liability after consideration of carryback from 1979 to 1978:
Investment tax credit carryback 444,727 0 444,727
Total credit carryback from 1979 to 1978 444,727 0 444,727
Tax liability after consideration of carryback from 1979 to 1978 6,164,080 6,608,807 (444,727)
Tax assessed and paid 3,633,741 3,633,741 0
Deficiency after consideration of credit carryback from 1979 to 1978 2,530,339 2,975,066 (444,727)
Tax liability after consideration of carryback from 1982 to 1978:
Current year investment tax credit (freed up) (541,122) (541,122) 0
Foreign tax credit carryback 1,971,695 1,971,695 0
Investment tax credit carryback/(freed up) (444,727) 0 (444,727)
Total credit carryback from 1982 to 1978 1,526,968 1,971,695 (444,727)
Tax liability after consideration of carryback from 1982 to 1978 5,178,234 5,178,234 0
Tax assessed and paid 3,633,741 3,633,741 0
Tax assessed 9/30/92 subsequent to Tax Court Decision 2,076,812 2,076,812 0
Total assessment 5,710,553 5,710,553 0
Overassessment after consideration of credit carryback from 1982 to 1978 (532,319) (532,319) 0
Tax assessed 9/30/92 subsequent to Tax Court Decision but not paid 2,076,812 2,076,812 0
Tax deficiency before taking into account 9/30/92 assessment, as
reflected in the Tax Court Decision dated November 17, 1994 1,544,493 1,544,493 0
Payments and credits applied after the Tax Court Decision 79,925 79,925 0
Deficiency after consideration of carryback from 1979 and 1982, and
payments subsequent to the November 17, 1994 Tax Court Decision 1,464,568 1,464,568 0
Determination of Deficiency
Tax liability
Tax liability without credit carrybacks 6,608,807 6,608,807 0
Current year investment tax credit (freed up) (541,122) (541,122) 0
Foreign tax credit carryback 1,971,695 1,971,695 0
Investment tax credit carryback/(freed up) 0 0 0
Total credit carryback 1,971,695 1,971,695 0
Tax liability after consideration of credit carryback from 1979 and 1982 5,178,234 5,178,234 0
Tax assessed and paid
Tax assessed and paid without consideration of events subsequent
to Tax Court Decision 3,633,741 3,633,741 0
Tax deficiency before taking into account 9/30/92 assessment, as
reflected in the Tax Court Decision dated November 17, 1994 1,544,493 1,544,493 0
Payments and credits applied after the Tax Court Decision 79,925 79,925 0
Deficiency after consideration of carryback from 1979 and 1982, and
payments subsequent to the November 17, 1994 Tax Court Decision 1,464,568 1,464,568 0
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