Intermet Corporation & Subsidiaries - Page 4




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          substantial portion of the specified liability losses that                  
          petitioner claimed in its 1992 tax return.  Petitioner                      
          subsequently conceded a portion of the disallowed specified                 
          liability losses, leaving for decision the status of                        
          $1,019,205.23 in purported specified liability losses incurred by           
          Lynchburg during 1992.                                                      
               The specified liability losses remaining in dispute consist            
          of the following items:                                                     
               Disallowed Specified Liability Losses         Amount                   
               State tax deficiencies                       $717,617.00               
               Interest on State tax deficiencies           299,412.63                
               Interest on Federal income tax deficiency       2,175.60               
               The State of Michigan imposes a Single Business Tax on every           
          person with business income in the State.  Mich. Comp. Laws Ann.            
          �208.1 to 208.23b (West 1986).  During 1992, Lynchburg paid the             
          aforementioned State taxes and interest to the State of Michigan            
          following an audit of its 1986, 1987, and 1988 Michigan Single              
          Business Tax returns.  During 1992, Lynchburg paid the                      
          aforementioned interest to the Internal Revenue Service (the IRS)           
          following an audit of petitioner’s consolidated Federal income              
          tax return for 1987 and in accordance with an agreed adjustment             
          to Lynchburg’s separate taxable income for that year.  In 1992,             
          Lynchburg properly deducted the additional State taxes and                  
          Federal and State interest described above under chapter 1 of the           
          Internal Revenue Code.                                                      






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