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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 be
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