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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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