- 2 - David R. Brennan, John K. Steffen, Susan B. Grupe, and Nathan P. Zietlow, for petitioner. Jack Forsberg, for respondent. RUWE, Judge: On March 26, 1992, respondent determined deficiencies in petitioner's Federal income taxes as follows: Taxable Year Ended Deficiency Feb. 28, 1987 $2,962,380 Feb. 29, 1988 3,592,402 Petitioner paid these deficiencies following receipt of its notice of deficiency and on June 1, 1992, filed a petition with this Court claiming an overpayment of income tax for each year. In International Multifoods Corp. v. Commissioner, 108 T.C. 25 (1997), we disposed of several issues in this case. In an order accompanying the release of our opinion, we granted respondent's motion to sever and hold the sole remaining issue in abeyance. This remaining issue requires us to decide whether the loss realized by petitioner on its sale of the stock of Paty S.A.-Produtos Alimenticios, Ltda.,1 on March 31, 1987, is to be sourced in the United States for purposes of computing 1Hereinafter, we shall refer to Paty S.A.-Produtos Alimenticios, Ltda., as Paty and to the issue in question as the Paty stock loss issue.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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