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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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