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Ellwest Stereo Theatres, Inc. of Kansas City, docket No. 3906-94
Additions to Tax
Sec. Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6653(a)(1) 6653(a)(2) 6656
1985 $29,850 $7,463 $1,492 $16,168 $2,985
Ellwest Stereo Theatres of Youngstown, Inc., docket No. 3908-94
Additions to Tax
Sec. Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6653(a)(1) 6653(a)(2) 6656
1985 $20,250 $5,062 $1,012 $10,968 $2,025
At trial petitioners conceded that they are liable for the
deficiencies. The only issues remaining for decision are:
(1) Whether petitioners are liable for additions to tax under
section 6651 for failure to file Forms 1042 (Annual Withholding
Tax Return for U.S. Source Income of Foreign Persons) in
connection with certain payments they made to foreign
corporations; (2) whether petitioners are liable for additions to
tax under section 6656 for failure to withhold and deposit the
Federal income taxes due on such payments; and (3) whether
petitioners are liable for additions to tax under section 6653(a)
for negligence or intentional disregard of rules or regulations.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the joint exhibits attached thereto
are incorporated herein by this reference. At the time the
petitions were filed the principal office or agency for each
petitioner was in Durand, Michigan. Most, if not all, of
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