T.C. Memo. 1999-36
UNITED STATES TAX COURT
PEOPLEFEEDERS, INC. AND SUBSIDIARIES, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10864-96. Filed February 4, 1999.
Held: Under the facts of this case, the fact that
respondent’s notice of deficiency indicated that
petitioner’s taxable years ended on June 30 of each
year rather than on the actual last day of petitioner’s
taxable years does not invalidate respondent’s notice
of deficiency and does not deprive the Court of subject
matter jurisdiction.
Held, further, Petitioner’s claimed $3,751,930 bad
debt deduction for petitioner's 1992 taxable year and
net operating loss carrybacks and carryforwards
relating thereto are denied.
Charles O. Cobb, Thomas M. Cryan, and Mark A. Krasner, for
petitioner.
Robert J. Burbank and Thomas C. Pliske, for respondent.
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