- 2 - deficiencies, additions to tax, and a penalty in petitioner’s Federal income taxes as follows: Docket No. 4256-98: Additions to Tax Sec.6653 Sec.6653 Penalty Year Deficiency (a)(1)(A) (a)(1)(B) Sec.6661 12/31/83 $2,406,964 –- –- –- 12/31/84 21,943 –- –- –- 12/31/85 472,184 –- –- –- 12/31/86 8,322,020 $468,607 * $2,098,710 12/31/87 17,295,902 980,439 * –- *50 percent of the interest due on $8,394,838 and $15,047,884 for 1986 and 1987, respectively. Docket No. 4866-98: Year Deficiency 12/31/88 $452,426 12/31/89 1,983,005 12/31/90 404,620 12/31/91 772,825 12/31/92 8,017,277 12/31/93 4,300,188 12/31/94 2,900,914 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. The issue for decision is whether petitioner is entitled to use the reserve method of accounting for bad debts under section 593 for the taxable years 1986 through 1994. Summary judgment is intended to expedite litigation and avoid unnecessary and expensive trials. Fla. Peach Corp. v. Commissioner, 90 T.C. 678, 681 (1988). Summary judgment may bePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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