T.C. Memo. 2002-176
UNITED STATES TAX COURT
MAINE YANKEE ATOMIC POWER COMPANY, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15446-98. Filed July 29, 2002.
Edwin A. Heisler and William K. McKinley, for petitioner.
Marvis A. Knospe and Barry Laterman, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COHEN, Judge: Respondent determined deficiencies of
$408,949 and $710,318 in petitioner’s Federal income tax for 1990
and 1991, respectively. After concessions, the remaining issue
for decision is whether petitioner is entitled to an investment
tax credit with respect to nuclear fuel assemblies placed in
service in 1990. Unless otherwise indicated, all section
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