§1151

Additionally, respondent argues that Congress specifically carved out land on which airports were located from the Federal public lands that were made available for Native selection under ANCSA and, therefore, deliberately excluded these lands from Native ownership. Section 45A defines “Indian reservation” as a reservation as defi

Additionally, respondent argues that Congress specifically carved out land on which airports were located from the Federal public lands that were made available for Native selection under ANCSA and, therefore, deliberately excluded these lands from Native ownership. Section 45A defines “Indian reservation” as a reservation as defi

1,121 1984 4,889 244 1 2 1,467 1 50 percent of the interest due on $931 for 1981, $543 for 1982, $3,735 for 1983, and $4,889 for 1984. 2 120 percent of the interest due on $3,735 for 1983, and $4,889 for 1984. Pursuant to the Tax Reform Act of 1986, sec. 1151(c)(1), Pub. L. 99-514, 100 Stat. 2744, former sec. 6621(d) was redesignated as sec. 6621(c). The deficiencies in this case arise from the disallowance of Schedule E losses and investment tax credits claimed by petitioners with respect to th

1151(c)(1), 100 Stat. 2744, former sec. 6621(d) was redesignated as sec. 6621(c). Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. -3- were entered into primarily for profit; (2) whether petitioners ar