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Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the subject years. Rule
references are to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulated facts and exhibits submitted therewith are
incorporated herein by this reference. Petitioner's principal
place of business was in San Anselmo, California, when it
petitioned the Court.
Petitioner was organized by Alfred Roven (Mr. Roven) on
October 20, 1980, primarily to transact business in the
securities market, buying and selling securities, bonds, and
derivatives, among other things. Mr. Roven is petitioner's sole
shareholder, as well as its president and one of its two
directors. Joy Martin (Ms. Martin) is petitioner's other
director, and she is its secretary and bookkeeper.
Mr. Roven organized Kenilworth Corp. (Kenilworth), on
January 12, 1982, to trade securities and to provide consulting
services on the trading of securities. Mr. Roven owns 40 percent
of Kenilworth's stock, and its remaining stock is equally owned
by two of his children. Kenilworth's taxable year ends on
May 31, and it began filing a consolidated income tax return with
a lone subsidiary effective with its taxable year ended May 31,
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Last modified: May 25, 2011