-2- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011