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in excess of $100,000 for petitioner’s tax year ended January 31,
1994. On October 6, 2000, respondent issued a notice of
deficiency to petitioner for its tax years ended January 31,
1994, 1995, and 1996. In the notice, respondent determined
deficiencies in petitioner’s corporate income tax of $225,753,
$111,191, and $184,219, respectively, for those years.
Respondent also determined that petitioner was liable for an
addition to tax under section 6651(a)(1) of $24,923.25 for the
tax year ended January 31, 1995.
Petitioner filed a petition and an amended petition with
this Court seeking a redetermination. In the petitions,
petitioner disputed the entire amounts determined by respondent
for the tax years ended January 31, 1994, and January 31, 1995,
and $14,745 of the amount determined for the tax year ended
January 31, 1996. Among other allegations, petitioner alleged
that it was entitled to an additional deduction of $900,000 for
the tax year ended January 31, 1995, for an accrued liability to
an insurance company. On the basis of this allegation,
petitioner alleged that it was entitled to an NOL of $605,067 for
the tax year ended January 31, 1995.
On March 18, 2002, the parties filed a stipulation of agreed
issues with the Court. Among other concessions, respondent
conceded that for the tax year ended January 31, 1995, petitioner
was entitled to an additional deduction of $900,000 and incurred
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