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MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge: Respondent determined deficiencies in
petitioner’s consolidated Federal income taxes in the respective
amounts of $28,415, $22,495, $465,115, $24,108, and $45,837
allegedly for petitioner's 1990, 1991, 1992, 1993, and 1994
taxable years.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
The issues for decision are: (1) Whether deficiency
determinations for petitioner's taxable years 1990 through 1994
were made in respondent’s notice of deficiency, as respondent
contends, or whether deficiency determinations against petitioner
for nonexistent years were made in respondent’s notice of
deficiency, as petitioner contends, making respondent’s
deficiency determinations defective and depriving the Court of
subject matter jurisdiction over petitioner's tax liabilities;
and (2) if the above issue is resolved in favor of respondent,
whether petitioner is entitled to a $3,751,930 claimed bad debt
deduction for petitioner's 1992 taxable year and net operating
loss (NOL) carrybacks and carryforwards relating thereto.
FINDINGS OF FACT
Some of the facts are stipulated and are so found.
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