- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011