- 31 -- 31 - 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 0Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31
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