Florida Industries Investment Corporation and Subsidiaries - Page 2




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          penalties under section 6662(a) on petitioners' Federal income               
          tax (tax), as follows:                                                       

                Taxable                                         Accuracy-              
               Year Ended      Deficiency Addition to Tax    Related Penalty           
            February 28, 1991   $133,316        $50,286          $40,228               
            February 29, 1992   59,808          5,981            11,962                
            February 28, 1994   158,230         39,558           31,646                

               The issues remaining for decision are:                                  
               (1)  Are petitioners entitled to nonrecognition treatment               
          under section 1031 with respect to certain gains realized by                 
          petitioner Orlando Industrial Properties, Inc. (OIP) during the              
          taxable year ended February 28, 1991, as a result of the disposi-            
          tion of certain real estate interests?  We hold that they are                
          not.                                                                         
               (2)  Are petitioners entitled to nonrecognition treatment               
          under section 1033 with respect to certain gain realized by OIP              
          during the taxable year ended February 28, 1991, as a result of              
          the condemnation of certain real property?  We hold that they are            
          not.                                                                         
               (3)  Are petitioners liable for the addition to tax under               
          section 6651(a)(1) for each of the taxable years at issue except             












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