- 2 - business. Held, further, P is liable for the accumulated earnings tax. Robert E. Miller and Edith S. Thomas, for petitioner. Alexandra E. Nicholaides and Eric R. Skinner, for respondent. MEMORANDUM OPINION LARO, Judge: Petitioner sought redetermination of deficiencies in Federal income taxes, additions to tax, and penalties determined by respondent as follows: Taxable Year Additions to Tax Penalty Ended Sec. Sec. Sec. August 31 Deficiency 6651(a)(1) 6653(a) 6662 1989 $124,721 $1,192 $11,396 --- 1990 208,903 1,487 --- $1,189 1991 216,364 36,336 --- 29,069 1992 16,706 --- --- --- After concessions by both parties, the issues for decision are:1 (1) Whether petitioner may deduct payments made to one of its ultimate beneficial owners as compensation for services. We hold that it may. (2) Whether petitioner is liable for accumulated earnings tax. We hold that it is liable with respect to 3 of the 4 taxable years at issue. (3) Whether petitioner is liable for additions to tax under sections 6651 and 6653(a) and for 1 Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the years at issue, and Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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