Diesel Performance, Inc. - Page 3




                                        - 3 -                                         

                                     Background                                       
               Diesel Performance, Inc. (Diesel Performance), is a                    
          corporation permitted to do business in California.  It was                 
          incorporated on January 2, 1973.                                            
               For the tax year ending June 30, 1992, petitioner timely               
          filed its corporate income tax return, Form 1120.  The originally           
          filed Form 1120 for the tax year ending June 30, 1992, showed a             
          profit (taxable income) for petitioner.                                     
               Due to accounting errors related to section 263A                       
          adjustments, petitioner's accountant discovered that the original           
          Form 1120 for the tax year ending June 30, 1992, was incorrect.             
          After discovering the error, petitioner prepared an amended Form            
          1120X for the tax year ending June 30, 1992, which was filed on             
          March 25, 1994.  The Form 1120X, for the first time, showed                 
          petitioner had actually sustained a loss for that period.                   
          Respondent does not dispute the accuracy of the loss reported on            
          petitioner's Form 1120X for the period ending June 30, 1992.                
               On the Form 1120X, petitioner attached a statement which               
          read:                                                                       














Page:  Previous  1  2  3  4  5  6  7  8  9  10  Next

Last modified: May 25, 2011