- 5 - pay higher commissions to cover the costs of those services. For Federal income tax purposes, petitioner reports income and deductions under the accrual method of accounting and has adopted the “recurring item exception” under section 461(h)(3). On February 9, 1987, petitioner qualified to do business in California and on April 1, 1987, began operations. Petitioner used a calendar year for California franchise tax purposes. Petitioner’s first tax year for Federal income tax purposes ended on March 31, 1988. In its second and successive years, petitioner’s tax year for Federal income tax purposes was changed to the calendar year. Petitioner’s California franchise tax liabilities were originally deducted on its Federal corporate income tax returns in the following manner: California California Income Franchise Computational Tax Base Federal Tax Year Tax Liability 1987 calendar year FYE 3/31/88 $879,500 1988 calendar year 1989 calendar year 932,979 1989 calendar year 1990 calendar year 1,806,588 1990 calendar year 1991 calendar year 2,066,547 1991 calendar year 1992 calendar year 3,778,547 1992 calendar year 1993 calendar year 5,578,718 Petitioner, on its Federal corporate income tax return for the short (9-month) year ended December 31, 1988, did not claim a California franchise tax deduction.Page: Previous 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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