UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT
filed: January 12, 1990.
AFFILIATED DEVELOPMENT CORP., APPELLANT
ANTHONY P. OLIVE, DIRECTOR OF VIRGIN ISLANDS BUREAU OF INTERNAL REVENUE, AND GOVERNMENT OF THE VIRGIN ISLANDS, APPELLEES
On Appeal from the District Court of the Virgin Islands, Civil No. 86-299.
Gibbons, Chief Judge, Mansmann and Nygaard, Circuit Judges.
Author: Per Curiam
Opinion OF THE COURT
Affiliated Development Corp., a Virgin Islands inhabitant foreign corporation, appeals from a judgment affirming deficiencies in income tax for the years ending November 30, 1982 and November 30, 1983, a penalty under 26 U.S.C. § 6661 for the year ending November 30, 1983, negligence penalties under 26 U.S.C. § 6653(a) for both years, and late filing penalties under 26 U.S.C. § 6051 for both years. The legal issues presented are discussed in the opinion filed in Business Ventures International Inc. v. Olive, 893 F.2d 641 (3d Cir. 1990). For the reasons set forth therein, the judgment appealed from will be reversed to the extent that it affirmed the assessed deficiencies and penalties for the year ending November 30, 1983, but affirmed to the extent it affirmed assessment of a deficiency in taxes, and penalties, for the year ending November 30, 1982.
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