-3-
are liable for the section 6662(a) accuracy-related penalty for
each of the years in issue.1
Background
The following facts have been stipulated and are so found.
The stipulations of fact and the attached exhibits are
incorporated herein by this reference. Petitioners filed joint
tax returns for the years in issue. Petitioners resided in
Pickens, South Carolina, on the date they filed their petition.
Petitioner is the founder of H. E. Stanley Pharmaceuticals
and Subsidiaries, hereinafter referred to as the company. The
company was founded to carry on work begun by petitioner's father
who was a medical missionary in Haiti. Its primary focus was the
manufacture and sale of preparations containing an ingredient
known as QRB-7 for the treatment of certain skin disorders.
Petitioner was the company's majority shareholder at least up to
a certain point in 1992. He was its president, chief executive
officer, and motivating force through the end of 1993. He was
the company's largest shareholder up to the time it ceased
operations.
1 Respondent also disallowed deductions of $32,121 for
unreimbursed employee business expenses in 1993 and legal fees of
$26,976 in 1994. Petitioners raised no issue as to these
disallowances in their petition and offered no evidence to
support them. We treat these disallowances as having been
conceded.
Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011