- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011