United Circuits, Inc. - Page 2

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               After concessions by the parties, the only issues remaining            
          for decision are whether petitioner is liable for the 1989 and              
          1990 accuracy related penalties for negligence and for a                    
          substantial understatement of income tax.                                   
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated, and the stipulated             
          facts are incorporated in our findings by this reference.                   
          Petitioner had its principal place of business in Ohio at the               
          time the petition was filed.  During the years in issue,                    
          petitioner was in the business of manufacturing circuit boards.             
               United Circuits, Inc. (UCI), was owned by Frank Schubert               
          (Schubert) and Gary Jump (Jump).  Schubert, the president of UCI,           
          was primarily responsible for overseeing the manufacturing                  
          process and ensuring that the waste produced from the                       
          manufacturing process was in compliance with Environmental                  
          Protection Agency standards.  Schubert's education and prior work           
          experience were in engineering.                                             
               Jump was the vice president and general manager of UCI.                
          Jump had various responsibilities that included reviewing UCI               
          financial information, making decisions about equipment                     
          purchases, and working with Schubert on manufacturing matters.              
          Jump received a degree in marketing.                                        
               UCI employed Davidson Audit Company (DAC) to perform                   
          accounting functions and to prepare UCI's financial statements              
          and tax returns.  Eleanor Northcutt (Northcutt), an employee of             




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