Eyefull Incorporated - Page 3

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          accuracy-related penalties for negligence under section 6662.  We           
          hold that it is liable.  Some of the facts have been stipulated             
          and are so found.  The stipulation of facts and joint exhibits              
          attached thereto are incorporated herein by this reference.                 
          Issue 1:  Compensation                                                      
                                     Background                                       
               Petitioner was incorporated under California law in 1984.              
          At the time the petition was filed, petitioner’s principal place            
          of business was in the city of Ontario, in San Bernardino County,           
          California.  Petitioner owns and operates an adult entertainment            
          complex comprising a nightclub, bookstore, video arcade, and live           
          peep show.  Petitioner is one of a large group of corporations in           
          the same industry (the Mohney Group) that are owned, directly or            
          indirectly, by Harry V. Mohney (Mohney), either alone or as one             
          of several beneficiaries of a trust.  During the years at issue,            
          petitioner’s stock was owned in equal shares by three Turks &               
          Caicos Islands holding companies, Fun Films Ltd., Tornado Trading           
          Inc., and Azid Trading Corp.  Each of these holding companies               
          was, in turn, wholly owned by the Amaranta Trust, a foreign trust           
          established by Mohney.  During the years at issue the trustee of            
          the Amaranta Trust was Andrew Newlands (Newlands) and the                   
          beneficiaries were Mohney and members of his family.  Under the             
          terms of the trust instrument Mohney had no control over trust              
          assets and no power to discharge the trustee or appoint his                 
          successor in the event that he retired.                                     




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