Maritime Grain and Trading, Limited - Page 2




                                        - 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

Last modified: May 25, 2011