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estimated tax payment for the succeeding taxable year pursuant to
section 301.6402-3(a)(5), Proced. & Admin. Regs.2
On August 19, 1994, respondent issued a notice of deficiency
to petitioner. In the notice, respondent determined deficiencies
in petitioner's income taxes for the taxable years 1990 and 1991
in the amounts of $34,279,695 and $1,893,325, respectively.3
On September 15, 1994, petitioner filed its income tax
return for 1993, as well as amended tax returns (Forms 1120X) for
1990 and 1991.
Petitioner claimed an increased overpayment in the amount of
$1,146,384 on its amended return for 1990 and made an election to
treat such increased overpayment as a credit to be applied as an
estimated tax payment for 1991 pursuant to section 301.6402-
3(a)(5), Proced. & Admin. Regs. The increased overpayment that
petitioner claimed for 1990 is largely attributable to
petitioner's claim of additional general business credits and
environmental tax credits.
Petitioner's amended return for 1991 and petitioner's income
tax return for 1993 are related in that the most significant item
reported on petitioner's amended return for 1991 is a carryback
2 For each of the years discussed, petitioner filed
consolidated income tax returns on Form 1120, U.S. Corporation
Income Tax Return.
3 As will be discussed shortly, the taxable years 1990 and
1991 are the subject of a petition filed at another docket.
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