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1985 and 1986 tax years and the holding in Shorthorn Genetic
Engg. 1982-2, Ltd. v. Commissioner, supra.
On the basis of the disallowed tax benefits claimed by
petitioner relating to SGE, respondent assessed income tax
deficiencies against petitioner in the amounts determined for
each year in each Form 4549A-CG. The tax years, the assessment
dates, and the amounts of income tax deficiencies assessed
petitioner are as follows:
Tax Year Assessment Date Assessment Amount
1982 4-6-1998 $3,183
1983 4-6-1998 4,483
1984 4-6-1998 5,863
1985 4-6-1998 6,861
1986 4-6-1998 9,697
1987 3-30-1998 319
Respondent prepared an Interest and Penalty Detail Report
for each tax year from 1982 through 1987 based on the total
amount of income tax assessed and the applicable interest rates
determined pursuant to section 6621. Each report shows in detail
the computations used to determine the amount of interest on
petitioner’s income tax deficiencies. The tax year of each
deficiency, the dates during which the interest accrued, and the
total amount of interest calculated are as follows:
Dates Interest Accrued Total Amount
Year From To of Interest
1982 4-15-1986 3-26-2001 $12,984.50
1983 4-15-1986 3-26-2001 18,361.00
1984 4-15-1986 3-26-2001 24,013.15
1985 6-9-1986 3-26-2001 27,474.28
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