- 9 - Tax-Exempt Interest; Dividends on Domestic Stock During the taxable years in issue, HEI received interest and dividends on tax-exempt obligations and domestic shares, respectively, held by the Investment Divisions. HEI deducted 70 percent of the dividends received on those domestic shares. Respondent's Adjustments Respondent proposes that we make the following adjustments to petitioner's claimed interest expense deductions and dividends received deductions: Tax Year Interest Expense Deduction Dividends Received Deduction Ending Claimed Disallowed Claimed Disallowed Sec. 265(a)(2) Sec. 246A 6/30/89 $18,197,732 $2,891,294 $393,201 $393,201 6/30/90 $17,580,023 $3,478,858 $587,781 $572,329 6/30/91 $13,862,253 $4,380,018 $337,410 $337,410 ULTIMATE FINDING OF FACT Based on the restructuring plan, the shareholder agreement, and the sequence of events that followed, we find that the dominant purpose for incurring the 1987 indebtedness was to purchase tax-exempt obligations and portfolio stock. OPINION I. Introduction We must determine whether section 246A applies to eliminate the dividends received deduction claimed by HEI with respect to dividends received on the domestic shares owned by it and whetherPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011