- 2 - 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),Page: Previous 1 2 3 4 5 6 Next
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