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MEMORANDUM FINDINGS OF FACT AND OPINION
RUWE, Judge: In docket No. 16379-94, respondent determined
a deficiency in L.L. Bean, Inc.'s (hereinafter petitioner) 1986
Federal income tax of $649,428. In docket No. 16380-94,
respondent issued a notice of final S corporation administrative
adjustment (FSAA) to Leon Gorman, petitioner's president and tax
matters person, setting forth the following disputed adjustments
with respect to petitioner's 1987 taxable year:1
Item FSAA Adjustment Amount in Dispute
Depreciation deduction $1,375,273 $608,037
General business credit 22,523 19,622
The sole issue for decision is whether petitioner is
entitled to an investment tax credit (ITC) under section 382 with
respect to certain property petitioner placed in service during
the years in issue.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts, first, second, and third supplemental
1Other adjustments set forth in the notice of final S
corporation administrative adjustment are not in dispute.
2Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable years in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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