Taiyo Hawaii Company, Ltd. - Page 9

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               Fiscal Year                                                            
               Ended                                                                  
               Sept. 30        Interest Paid           Tax Withheld                   
               1989           $838,037.66         $83,803.77                          
               1990      1,451,660.54             145,166.06                          
               1991      941,821.13               94,182.11                           
               On or about June 14, 1995, petitioner filed amended 1989,              
          1990, and 1991 Federal income tax returns.  On the amended                  
          returns, petitioner claimed deductions for interest expense                 
          related to its ECI from the conduct of a trade or business in the           
          United States, as follows:                                                  
               Fiscal Year                                                            
               Ended                                                                  
               Sept. 30                   Interest Deducted                           
               1989                          $834,750                                 
               1990                          1,307,734                                
               1991                          1,348,414                                

               On amended returns, petitioner reported the sum of its                 
          assets and liabilities, as follows:                                         
                    Fiscal Year                                                       
                    Ended          Net Liabilities                                    
                    Sept. 30           Over Assets1                                   
                    1989      ($8,211,833)                                            
                    1990          (8,917,909)                                         
                    1991           (7,143,782)                                        
                                                                                     
               1These amounts were derived from Schedule L of petitioner's            
          amended Federal income tax returns.                                         
          Petitioner's amended returns for 1989, 1990, and 1991, reflected            
          its net income or loss (prior to the deduction for interest                 
          expense) and gain or loss on its ECI, without considering net               
          operating loss deductions, as follows:                                      




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