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CENTRAL DE GAS DE CHIHUAHUA v. COMMISSIONER

Docket No. 18370-91.

102 T.C. 515 (1994)

CENTRAL DE GAS DE CHIHUAHUA, S.A., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 4, 1994.

Attorney(s) appearing for the Case

George W. Connelly, Jr., and Linda S. Paine, for petitioner.

T. Richard Sealy III, for respondent.

OPINION

TANNENWALD, Judge:

After making a jeopardy assessment, respondent determined a deficiency of $696,240 in petitioner's Federal income tax for its 1990 taxable year under section 881.1 The case comes before us on cross-motions for summary judgment on the issue of whether the 30-percent tax imposed by section 881 applies in the absence of an actual payment of the income item...

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