- 3 -
Year Deficiency
1987 $26,200,358
1988 13,827,654
1989 6,225,404
1990 23,466,338
Petitioner claims overpayments of $57,775,538 for 1987,
$28,434,990 for 1988, $32,577,346 for 1989, and $19,504,333 for
1990.
Petitioner and respondent filed cross-motions for partial
summary judgment under Rule 1211 on the question of whether
petitioner is entitled to amortize the economic benefit of
certain debt obligations which had below-market interest rates on
January 1, 1985, the date petitioner became subject to Federal
income taxation. Petitioner claims entitlement to amortize its
favorable financing using a fair market value basis as of that
date. Petitioner determined the fair market value of the claimed
favorable financing to total $456,021,853 on January 1, 1985, and
claims the following amortization deductions for taxable years
1985 through 1990:
1All Rule references are to the Tax Court Rules of Practice
and Procedure, and all section references are to the Internal
Revenue Code in effect for the taxable years in issue, unless
otherwise indicated.
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