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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.
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