- 69 - 17. Petitioner must recognize additional "interest income", computed under section 482, for year ending June 30, 1989, in the amount of $150,000. The $150,000 is subject to an addition to tax under section 6651(a)(1). The additions to tax under sections 6653(a)(1) and 6661(a) do not apply to the $150,000. 18. Petitioner does not have to recognize any "interest income", computed under section 482, for years ending June 30, 1990, 1991, and 1992. The penalties under section 6662(a), (d) do not apply to the "interest income", computed under section 482, for years ending June 30, 1990 and 1991. There are no additions to tax under section 6651(a)(1) and (2), or penalty under section 6662(a) relating to the "interest income", computed under section 482, for year ending June 30, 1992. 19. Section 59A controls the environmental tax deduction, and that deduction will be calculated based on the Court's final determination as to the taxable income for years ending June 30, 1989, 1990, 1991, and 1992. 20. For the years in issue, petitioner was a member of a controlled group, as defined in section 1563. The income tax brackets, environmental tax exemptions, and any other tax benefits described in section 1561, will be allocated equally among the members of the controlled group as specified in section 1561 for years ending June 30, 1989, 1990, 1991, and 1992. For years ending June 30, 1989 and 1990, the controlled group consisted of petitioner and Apollo Produce Distributing, Inc. For years ending June 30, 1991 and 1992, the controlled group consisted of petitioner, Apollo Produce Distributing, Inc., and RCLA, Inc.Page: Previous 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69
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