Southern MultiMedia Communications, Inc. - Page 2




                                        - 2 -                                         
               SWIFT, Judge:  For the years in issue, respondent determined           
          deficiencies in petitioners' Federal income taxes as follows:               

                             Year           Deficiency                               
                              1990           $3,318,947                               
                              1991           1,512,979                                
                              1992           2,272,661                                
                              1993           2,727,882                                

               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.                                                                  
               After settlement of some issues, the issue remaining for               
          decision is whether costs of certain improvements to petitioners’           
          cable television systems qualify for investment tax credit (ITC)            
          under the supply or service transition rule of section 204(a)(3)            
          of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2085,              
          2149.                                                                       

                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
               Petitioners constitute an affiliated group of companies                
          engaged in the cable television business.  During the taxable               
          years in issue, Wometco Cable Corp., a Delaware corporation, was            
          the common parent of the affiliated group of companies and                  
          maintained its principal office in Miami, Florida.  Hereinafter,            
          petitioners will be referred to simply as Wometco.                          





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  Next

Last modified: May 25, 2011