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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:
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Last modified: May 25, 2011