- 4 -
of a short-term capital loss claimed on petitioner's income tax
return for 1993. In particular, petitioner reported short-term
capital gain of $1,543,914 and short-term capital loss of
$35,234,914 on its income tax return for 1993. A large portion
of the net of these items; i.e., net short-term capital loss in
the amount of $32,797,961, is claimed as a carryback loss on
petitioner's amended return for 1991, which amended return
includes petitioner's claim for an increased overpayment for 1991
in the amount of $12,621,181.4 Petitioner made an election to
treat the $12,621,181 overpayment claimed on its amended return
for 1991 as a credit to be carried forward and applied as an
estimated tax payment for 1992 pursuant to section 301.6402-
3(a)(5), Proced. & Admin. Regs.
Petitioner's income tax return for 1993 reports total tax of
$75,758,778 and various tax credits totaling $83,577,768,
resulting in a claimed overpayment of $7,818,990. Among the
credits reported on petitioner's income tax return for 1993 is a
credit in the amount of $20,350,630, which is identified as a
credit for an overpayment of tax reported on petitioner's income
tax return for 1992. The $20,350,630 amount consists of the
$12,621,181 overpayment claimed on petitioner's amended return
4 The overpayment of $12,621,181 claimed on petitioner's
amended return for 1991 includes the carryforward of the
overpayment in the amount of $1,146,384 claimed on petitioner's
amended return for 1990.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011