- 30 -
involves reviewing invoices to document the acquisition of assets
and the sale documents which relate to the assets acquired. The
agent further testified that he was unable to reconcile the
assets listed on the schedule with the assets listed on the
returns. Likewise, we have examined the schedules but are unable
to ascertain which assets have been sold. Petitioner’s records
are inadequate for purposes of the ITC, and accordingly we
sustain respondent’s determination that petitioner is not
entitled to a $64,291 ITC carryover from its 1991 to its 1992
taxable year.
Jobs Credit
Findings of Fact
Petitioner claimed a jobs credit carryover in 1992 of
$25,500. Respondent determined that the jobs credit carryover
from 1991 to 1992 was $25,304 rather than $25,500.
Discussion
Petitioner claimed a jobs credit carryover in 1992 of
$25,500. Respondent determined that jobs credits were previously
used in the 1989, 1990, and 1991 taxable years, leaving only
$25,304 available for 1992. Accordingly, respondent disallowed
$196 of the jobs credit carryover claimed by petitioner in 1992.
On brief, petitioner conceded this issue. Thus, respondent’s
determination on this issue is sustained.
Page: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 NextLast modified: May 25, 2011