Med James, Inc. - Page 1

                                   121 T.C. No. 9                                     


                               UNITED STATES TAX COURT                                


                           MED JAMES, INC., Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 366-01.               Filed September 9, 2003.              

                    R sent P a 30-day letter proposing a deficiency in                
               excess of $100,000 for P’s tax year ended Jan. 31,                     
               1994.  R subsequently issued a notice of deficiency to                 
               P determining deficiencies in P’s corporate income                     
               taxes for its tax years ended Jan. 31, 1994, 1995, and                 
               1996.  P filed a petition to this Court.  R and P                      
               stipulated that P’s deficiency in income tax for the                   
               tax year ended Jan. 31, 1994, computed before allowance                
               for a net operating loss (NOL) carryback from the                      
               subsequent tax year was $225,753.  After allowance for                 
               the NOL carryback, P’s deficiency for the tax year                     
               ended Jan. 31, 1994, was $63,573.  The Court entered a                 
               decision that there was a deficiency in income tax due                 
               from P for the tax year ended Jan. 31, 1994, of                        
               $63,573.  The decision became final on Sept. 3, 2002,                  
               and R then assessed the $63,573 deficiency plus                        
               interest.  R applied the increased interest rate under                 
               sec. 6621(c), I.R.C., for the period beginning 30 days                 
               after the 30-day letter was sent.  P paid the                          
               deficiency and interest. On Mar. 17, 2003, P filed a                   
               motion to redetermine interest.                                        





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