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Conclusion ......................... 204
Appendix A: Equipment Installed at Substations ....... 205
Appendix B: DRI Project .................. 208
MEMORANDUM FINDINGS OF FACT AND OPINION
RUWE, Judge: Respondent determined the following
deficiencies in petitioner’s Federal income taxes:
Year Deficiency
1988 $922,601
1989 15,183,930
1990 5,228,640
1991 1,788,565
1992 5,867,463
Petitioner did not make any claim for investment tax credits
(ITCs) in its original returns for the taxable years 1988, 1989,
and 1990. On the same date that respondent issued the notice of
deficiency, petitioner filed Forms 1120X, Amended U.S.
Corporation Income Tax Returns (amended returns), for its taxable
years 1988, 1989, and 1990. In the amended returns, petitioner
claimed additional ITCs1 as follows:
Year Amount
1988 $33,308,287
1989 44,336,798
1990 55,760,749
On March 21, 1996, petitioner filed its petition in this
case listing these same amounts. In its first and second amended
1 In the amended returns, petitioner claimed refunds.
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