- 2 - 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.Page: Previous 1 2 3 4 Next
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