- 2 - Respondent filed a Notice of Objection to Petitioner’s Motion for Partial Summary Judgment and Respondent’s Memorandum of Authorities. Petitioner filed Petitioner’s Reply to Respondent’s Notice of Objection to Petitioner’s Motion for Partial Summary Judgment. As explained more fully below, we will deny petitioner’s Motion for Partial Summary Judgment. Background By a notice of deficiency mailed to petitioner on July 1, 1998, respondent determined deficiencies in Federal income taxes due from petitioner for the fiscal years ended February 28, 1993 and 1994 in the amounts of $217,280 and $126,017, respectively. Petitioner timely filed a petition in this case on February 19, 1999, and respondent timely answered on April 12, 1999. Limited Gaming of America, Inc., hereinafter referred to as LGA or petitioner, is a Colorado corporation originally formed on May 5, 1991. LGA is a “C” corporation; it has a fiscal year ending on February 28. On or about January 4, 1994, LGA caused to be formed Sunrise Island Timber Company, hereinafter referred to as Sunrise, a Florida general partnership, for the purpose of holding real property consisting of an island located in the Mississippi River. Sunrise was subsequently converted to a Florida limited partnership in February 1995.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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