- 2 - In the notice of deficiency, respondent determined deficiencies in and penalties on petitioner's Federal income tax as follows: Taxable Accuracy-related Year Ending Penalties June 30 Deficiency Sec. 6662 1991 $225,794 $45,159 1992 318,517 63,703 1993 379,025 75,805 Petitioner has its principal place of business in Chamblee, Georgia. Prior to the issuance of the notice of deficiency and in accordance with section 534(b), respondent issued to petitioner a Notice of Intent to Assert Accumulated Earnings Tax stating that respondent intended to issue a notice of deficiency for the tax on accumulated earnings pursuant to section 531. Petitioner submitted a timely statement pursuant to section 534(c). Subsequently, respondent issued a notice of deficiency in which respondent determined, inter alia, that petitioner is liable for the accumulated earnings tax pursuant to section 531 for petitioner's taxable years ended June 30, 1991, 1992, and 1993. Petitioner filed a petition with this Court, and respondent filed an answer. After the instant case was calendared for trial, respondent filed the instant motion to shift the burden of proof. 1(...continued) are to the Internal Revenue Code as in effect for the taxable years before the Court, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011