Doug-Long, Inc. v. Commissioner
United States Tax Court
Prior to issuing the statutory notice, respondent notified petitioner of proposed deficiencies in its income tax and accumulated earnings tax for 1974. Petitioner protested a portion of the income tax deficiency and the entire accumulated earnings tax deficiency to the District Director.
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Prior to issuing the statutory notice, respondent notified petitioner of proposed deficiencies in its income tax and accumulated earnings tax for 1974. Petitioner protested a portion of the income tax deficiency and the entire accumulated earnings tax deficiency to the District Director. Petitioner subsequently conceded the entire income tax deficiency, and in a prior opinion (72 T.C. 158), we held that petitioner was liable for accumulated earnings tax for 1974. Held: In calculating petitioner's "accumulated taxable income" for 1974, the portion of the income tax deficiency which was…
1Opinion of the Court
SUPPLEMENTAL OPINION
Hall, Judge:
On April 23, 1979, we filed our original opinion (72 T.C. 158) in this case. In his statutory notice, respondent determined the following deficiencies and additions for accumulated earnings tax for petitioner:
Accumulated earnings tax Deficiency Year
$12,020.25 $209.84 1972
10,168.85 0 1973
29,869.56 8,387.70 1974
In our original opinion, we held that petitioner was liable for the accumulated earnings tax under section 5311 for the years 1972, 1973, and 1974. To reflect adjustments in respondent’s determination which were set forth in our opinion, decision was to be…
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