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Year Deficiency Accuracy-Related Penalty
1989 $377,763 $75,553
1990 428,261 85,652
We must decide whether respondent's determinations for each
of the years at issue should be sustained. We hold that they
should.
This case was submitted fully stipulated. The several facts
that have been stipulated are so found.
Petitioner is a corporation organized under the laws of the
United Kingdom. At the time of the filing of the petition in
this case, petitioner's mailing address was in Los Angeles,
California.
Petitioner filed Form 1120F, U.S. Income Tax Return of a
Foreign Corporation, for each of its taxable years 1989 (1989
Form 1120F) and 1990 (1990 Form 1120F)2 and an amended Form 1120F
for its taxable year 1990 (1990 amended Form 1120F). In both its
1989 Form 1120F and its 1990 amended Form 1120F, petitioner
listed its address and the location of its books and records as
Los Angeles, California.
In completing its 1989 Form 1120F and its 1990 amended Form
1120F, petitioner was required to report items of income and
expense either in section I of that form entitled "Certain Gains,
Profits, and Income From U.S. Sources That Are NOT Effectively
2The record does not include petitioner's 1990 Form 1120F.
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Last modified: May 25, 2011