119 T.C. No. 2
UNITED STATES TAX COURT
METRO LEASING AND DEVELOPMENT CORPORATION, EAST BAY
CHEVROLET COMPANY, A CORPORATION, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent*
Docket Nos. 8054-99. Filed July 17, 2002.
In an earlier opinion, we decided that P permitted
its 1995 earnings to accumulate beyond the reasonable
needs of its business. Secs. 531-537, I.R.C. There
remains, however, a dispute concerning the computation
of the accumulated earnings tax. P contends,
alternatively, that R failed to reduce P’s accumulated
earnings tax base by the following amounts: (1)
“Deferred” tax attributable to installment sale
proceeds to be received by P in tax years after 1995;
(2) the amount of the income tax deficiency determined
by respondent which remains contested by P and for
which P has made payment after filing its petition; and
(3) the difference between the amount of tax liability
reported on P’s return and the amount of tax that would
have been due on P’s net capital gain.
*This Opinion supplements a previously released opinion:
Metro Leasing & Dev. Corp., East Bay Chevrolet Co., A Corporation
v. Commissioner, T.C. Memo. 2001-119.
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