- 3 - 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.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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