Taiyo Hawaii Company, Ltd. v. Commissioner

Gerber, Judge:

For the taxable years ended September 30, 1989, 1990, and 1991, 1 respondent determined deficiencies in petitioner’s Federal income taxes in the amounts of $35,529, $71,692, and $84,331, respectively. Respondent also determined an $8,433 addition to tax under section 6651(a)(1) 2 for 1991.

The issues for our consideration are: (1) Whether petitioner is liable for excess interest tax under section 884(f)(1)(B) for 1989, 1990, and 1991; (2) if petitioner is liable for the excess interest tax, whether certain assets should be included in the taxable base; and (3) whether petitioner…