Forkston Fireworks Mfg. Co., Inc. - Page 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.                   
               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                  
               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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