- 2 - the deduction allowable under this paragraph, but only if it has previously been returned as income.” P’s accrued interest, which was accrued when P was tax exempt and not required to file income tax returns, was not “returned as income” within the meaning of sec. 1.166-6(a)(2), Income Tax Regs., and P is not entitled to increase its regular adjusted cost basis for these amounts. Robert A. Rudnick, Stephen J. Marzen, James F. Warren, and Neil H. Koslowe, for petitioner. Gary D. Kallevang, for respondent. OPINION RUWE, Judge: Respondent determined deficiencies in petitioner’s Federal income taxes in docket No. 3941-99 for 1985 and 1986, as follows: Year Deficiency 1985 $36,623,695 1986 40,111,127 Petitioner claims overpayments of $9,604,085 for 1985 and $12,418,469 for 1986. Respondent determined deficiencies in petitioner’s Federal income taxes in docket No. 15626-99 for 1987, 1988, 1989, and 1990, as follows:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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