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ASA INVESTERINGS PSHIP. v. COMMISSIONER

Docket No. 27320-96.

118 T.C. 423 (2002)

118 T.C. No. 26

ASA INVESTERINGS PARTNERSHIP, ALLIEDSIGNAL, INC., TAX MATTERS PARTNER, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 22, 2002.

Attorney(s) appearing for the Case

Jerome Bernard Libin, Steuart Hill Thomsen, David A. Roby, Jr., Robert S. Chase II, William Sanford Corey, Alexa Temple Dubert, H. Karl Zeswitz, Jr., and Joseph M. Persinger, for petitioner.

Jill A. Frisch, for respondent.

OPINION

RUWE, Judge:

On October 3, 2001, petitioner, AlliedSignal, Inc., filed a motion to redetermine interest under section 7481(c) and Rule 261.1 Petitioner claims to have overpaid deficiency interest in the following amounts and for the following tax years:

  Tax year                          Interest

    1988 .........................   $415,714...

                    
                    
                    

                        

                            

                                
                            

                            

                                

                                    
    
                                        
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