- 4 - 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.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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