Fountain Valley Transit Mix, Inc. - Page 2

          entitled to a deduction as a trade or business expense of the               
          cost of purchasing tires which it contends were for use on leased           
          trucks; and (2) whether petitioner is liable for an accuracy-               
          related penalty under section 66621 as determined by respondent.            
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are found                   
          accordingly.                                                                
               Petitioner, Fountain Valley Transit Mix, Inc., is a                    
          California corporation.  At the time of the filing of the                   
          petition in this case, petitioner maintained its principal place            
          of business in Fountain Valley, California.  Petitioner filed its           
          Federal income tax return for its fiscal year ending June 30,               
          1990, with the Internal Revenue Service Center in Fresno,                   
          California.                                                                 
               Petitioner was incorporated in June 1987 and operated a                
          ready-mixed concrete business in southern California during its             
          fiscal year ending June 30, 1990.  Petitioner produced and                  
          delivered ready-mixed concrete to unrelated third-party                     
          contractors who had building projects in the southern California            
          area.                                                                       
               During its fiscal year 1990, petitioner was owned half by              
          Mr. Kurt Caillier (Kurt Caillier) and half by Kurt Caillier's               
          brother, Mr. Randy Caillier (Randy Caillier).  In 1990, Kurt                

          1  All section references are to the Internal Revenue Code                  
          in effect for the year in issue, and all Rule references are to             
          the Tax Court Rules of Practice and Procedure, unless otherwise             
          indicated.                                                                  




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011