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MEMORANDUM FINDINGS OF FACT AND OPINION
FOLEY, Judge: By notice dated April 21, 1999, respondent
determined the following deficiencies relating to petitioners’
Federal income taxes:
Reginald and Ronda Charlson, docket No. 12840-99
Year Deficiency
1994 $125,027
1995 26,775
1996 30,058
Great American Stageline, Inc., docket No. 12905-99
Year Deficiency
1995 $25,749
1996 38,652
1997 841
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 concessions, the issue for decision is whether
any petitioner is entitled to an investment tax credit (ITC) that
was carried forward from 1985.
FINDINGS OF FACT
When their respective petitions were filed, Reginald and
Ronda Charlson resided in Westlake Village, California, and Great
American Stageline, Inc. (Great American), had its principal
place of business in Newbury Park, California.
The Charlsons owned two corporations, Great American, a C
corporation, formed in 1974, and C & C Investments, Inc. (C & C),
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