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short-term capital loss from 1993 to 1991 that petitioner claimed
on its amended return for 1991.
On August 12, 1996, respondent issued a notice of deficiency
to petitioner in which respondent determined deficiencies in
petitioner's income taxes for 1992 and 1993 in the amounts of
$4,629,260 and $12,696,027, respectively. The notice of
deficiency includes the disallowance of the entire $35,234,914
short-term capital loss claimed by petitioner on its 1993 income
tax return for 1993.
On November 12, 1996, petitioner commenced the present case
by filing a timely petition for redetermination, contesting
respondent's determinations as set forth in the notice of
deficiency for 1992 and 1993. The petition includes allegations
that respondent erred in failing to recognize petitioner's
election to treat the $12,621,181 overpayment claimed on its
amended return for 1991 as a credit to be applied as an estimated
tax payment for succeeding taxable years.
Respondent has not issued a notice of deficiency to
petitioner for either 1994 or 1995.
On December 30, 1996, respondent issued to petitioner a
notice of intent to levy, which states that petitioner owes
$2,082,646 in tax, penalties, and interest for 1993.7 In
7 The difference between the $5,455,695.74 amount listed as
due for 1993 in respondent's bill to petitioner dated Dec. 19,
(continued...)
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