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the interest amounts petitioner reported on the Forms 5472 filed
with its Forms 1120X.
Petitioner timely petitioned this Court, alleging that
respondent’s determinations were in error. On June 13, 2005,
petitioner filed an amendment to its petition specifically
alleging that respondent erroneously calculated the deficiencies
for the years in issue because the Forms 5472 upon which
respondent relied reported interest paid to both GXE and GITIC.
In connection with the trial that followed, the parties
stipulated documentation of certain wire transfers during 1995
and 1996 and excerpts from petitioner’s general ledgers for 1995
and 1996. The exhibits reflect that petitioner made the
following interest payments on the GITIC and GXE loans during
1995 and 1996:
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