- 2 - Additions to Tax Year Deficiency Sec. 6651(a)(1) Sec. 6656 1990 $ 5,823 $ 1,456 $ 582 1991 136,238 34,060 13,624 1992 479,445 119,861 47,945 1993 265,732 66,433 26,573 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. After concessions, the issues for decision are whether, under sections 894, 1441, and 1442 and under a treaty between the United States and Canada, interest paid by petitioner is subject to withholding tax and whether petitioner is liable for additions to tax for failure to timely file withholding tax returns and for failure to make deposit of withholding taxes. FINDINGS OF FACT Some of the facts have been stipulated and are so found. At the time the petition was filed, petitioner’s principal place of business was located in Ontario, Canada. Petitioner (Del Commercial) was incorporated in the State of Illinois. Del Commercial invested in and owned industrial real property located in the United States and leased the property to tenants. In 1990, Del Commercial participated in a series of related and essentially simultaneous financial transactions with a number of its affiliated foreign corporations. As set forth in thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011