Cordes Finance Corporation - Page 2

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                      After concessions, the issues for decision are:  (1)                               
                Whether respondent abused her discretion under section                                   
                446(b) in computing an adjustment to change petitioner's                                 
                method of accounting for interest income from its                                        
                automobile finance business; (2) whether petitioner is                                   
                entitled to deduct a loss of $336,912 that was claimed on                                
                its amended return; (3) whether petitioner is liable for                                 
                the civil fraud penalty under section 6663(a); and (4)                                   
                whether petitioner is liable for the accuracy-related                                    
                penalty under section 6662(a) due to a substantial                                       
                understatement of income tax.                                                            

                                          FINDINGS OF FACT                                               
                      Some of the facts have been stipulated by the parties.                             
                The stipulation of facts, the supplemental stipulation of                                
                facts, and the exhibits attached thereto are incorporated                                
                herein by this reference.                                                                
                      Petitioner was incorporated in Oklahoma on January 24,                             
                1964, for the purpose of engaging in the business of                                     
                automobile financing.  At the time its petition was filed                                
                in this Court, petitioner's principal place of business                                  
                was in Lawton, Oklahoma.  Petitioner reported income and                                 
                expenses for Federal income tax purposes on the basis of                                 
                the accrual method of accounting and used the calendar year                              
                as its taxable year.                                                                     





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