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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 issue of whether, for
purposes of claiming a bad debt deduction under section 166,
petitioner is entitled to increase its regular adjusted cost
basis in certain mortgages acquired before January 1, 1985, for
unpaid interest which accrued during the period that petitioner
was tax exempt.
Background
The facts have been stipulated and are so found. The
stipulation of facts and the attached exhibits are incorporated
herein by this reference. At the time of filing the petition,
petitioner’s principal office was located in McLean, Virginia.
At all relevant times, petitioner was a corporation managed by a
board of directors.
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.
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Last modified: May 25, 2011