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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.
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