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Albert H. Turkus, Pamela F. Olson, William F. Nelson, and
Anne E. Collins, for petitioner.
John A. Guarnieri, Craig Connell, and Ruth M. Spadaro, for
respondent.
OPINION
RUWE, Judge: The matter is before the Court on petitioner’s
motion for summary judgment.
I. Introduction
Petitioner is a Delaware corporation, with its principal
place of business in Wayne, New Jersey. It is the common parent
of an affiliated group of corporations making a consolidated
return of income (the affiliated group).
By notice of deficiency dated September 12, 1997, respondent
determined deficiencies in the Federal income tax liabilities of
the affiliated group for its taxable (calendar) years 1987, 1988,
and 1990, in the amounts of $4,038,474, $70,644, and $80,285,840,
respectively, along with an accuracy-related penalty for 1990 of
$16,057,168.1 Petitioner asks for summary disposition in its
favor on the ground that this is not a partnership proceeding,
and respondent has determined deficiencies that are entirely
1Respondent concedes that the adjustment for 1988 was made
in error and that no deficiency exists for that year.
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