- 18 - petitioner’s 1993 Schedule C. In the fall of 1996, respondent began an examination of petitioner’s taxable years ended June 30, 1990, 1991, 1992, and 1993. On October 8, 1996, petitioner mailed to respondent a letter on petitioner’s letterhead, entitled “STATEMENT FURNISHED UNDER REVENUE PROCEDURE 94-69", which respondent received on October 11, 1996 (October 11, 1996 disclosure letter). Price Waterhouse had drafted that letter. The October 11, 1996 disclo- sure letter stated in pertinent part: As previously disclosed to the Internal Revenue Service (IRS) in July 1995, and on September 24, 1996, InterTAN, Inc. [petitioner] is facing under Internal Revenue Code Section 905(c) a potential redetermination of the foreign tax credits claimed on its U.S. income tax returns for the years ended June 30, 1990 through June 30, 1993. The redetermination could arise from a potential deficit in the post-1986 pool of foreign taxes for InterTAN Canada Ltd. (InterTAN Canada) [ITC]. In this eventuality, InterTAN, Inc.’s foreign tax credits would be required to be redetermined pursuant to Treasury Regulation Section 1.905-3T(d)(4)(iv) with notification made by InterTAN Inc. pursuant to Treasury Regulation Section 1.905-4T(b). The dividends paid by InterTAN Canada from the 1988 through 1992 tax years are as follows: Deemed-paid Tax Type of Foreign Tax Grossed-up Year Dividend Amount Credit Dividend 1988 Preferred $23,910,500 $15,720,834 $39,631,334 Stock Redemption 1989 Preferred 13,570,739 8,745,782 22,316,521 Stock Redemption 1992 Preferred 20,000,000 18,236,696 38,236,696 Stock RedemptionPage: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
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