- 2 -
1982 4,052,244
1983 3,042,955
1984 2,493,442
1985 1,087,116
The sole issue for decision is whether petitioner is liable
under sections 14411 and 1461 for withholding taxes on interest
payments made to nonresident aliens.
FINDINGS OF FACT
Petitioner and Other Entities
Some of the facts have been stipulated and are so found. We
incorporate by this reference the stipulation of facts and the
related exhibits.
At the time of filing the petition, petitioner (AmBase
Corporation) was a Delaware corporation that maintained its
principal office in Greenwich, Connecticut. Petitioner assumed
the Federal withholding tax liabilities of City Investing Co.
(City) upon the liquidation of City in 1985.
City was incorporated in Delaware in 1967 and succeeded,
through a merger in 1968, to a corporation of the same name
incorporated in 1904. During the late 1970's, City was a
multinational holding company with assets on a consolidated basis
exceeding $4.2 billion and net equity of approximately $800
million. City engaged through its subsidiaries in manufacturing,
housing, insurance, and other financial enterprises. City’s
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years at issue.
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