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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