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Moshe Schuldinger, for petitioner.
Alan R. Peregoy, for respondent.
MEMORANDUM OPINION
CHABOT, Judge: The instant case is before us on
respondent’s motion under Rule 1211 for summary judgment.
Background--Procedure
Respondent determined a deficiency in Federal corporate
income tax against petitioner for 1990 in the amount of $33,208
and an addition to tax under section 66622 (negligence or
substantial understatement of income tax) in the amount of
$6,642.
Petitioner invoked this Court’s jurisdiction by filing a
timely petition from the notice of deficiency, disputing the
entire amounts of the deficiency and addition to tax. In the
notice of deficiency, respondent determined that petitioner had
$119,318 in unreported gross sales, but that petitioner was
entitled to $6,384 in miscellaneous unclaimed deductions, for net
adjustments of $112,934. In the petition, petitioner contends
that (1) it does not have any additional 1990 income subject to
tax, and (2) it is entitled to more 1990 deductions than
1 Unless indicated otherwise, all Rule references are to
the Tax Court Rules of Practice and Procedure.
2 Unless indicated otherwise, all section references are
to sections of the Internal Revenue Code of 1986 as in effect for
the year in issue.
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