Warbelow's Air Ventures - Page 2




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               Michael J. Walleri, for petitioner.1                                   
               Stephen P. Baker, for respondent.                                      
                                       OPINION                                        
               VASQUEZ, Judge:  Respondent determined the following                   
          deficiencies in petitioner’s Federal income taxes:                          
                    TYE Apr. 30              Deficiency                               
                    1996                     $12,482                                  
                    1997                8,369                                         
                    1998                355                                           
          The issue for decision is whether petitioner qualified for the              
          Indian employment credit (IEC) pursuant to section 45A for its              
          fiscal years ended April 30, 1996 (TY 1996), April 30, 1997 (TY             
          1997), and April 30, 1998 (TY 1998).2                                       
          Background                                                                  
               The parties submitted this case fully stipulated pursuant to           
          Rule 122.  The stipulation of facts and the attached exhibits are           
          incorporated herein by this reference.  At the time the petition            
          was filed, petitioner had its mailing address and principal                 
          office in Fairbanks, Alaska.                                                
               The city of Galena (Galena) is located approximately 270               
          miles west of Fairbanks on the north bank of the Yukon River.               


               1  Mr. Walleri began representing petitioner on Oct. 12,               
          2001.                                                                       
               2  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.                              





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