- 2 - After concessions, the issues for decision are: (1) Whether respondent abused her discretion under section 446(b) in computing an adjustment to change petitioner's method of accounting for interest income from its automobile finance business; (2) whether petitioner is entitled to deduct a loss of $336,912 that was claimed on its amended return; (3) whether petitioner is liable for the civil fraud penalty under section 6663(a); and (4) whether petitioner is liable for the accuracy-related penalty under section 6662(a) due to a substantial understatement of income tax. FINDINGS OF FACT Some of the facts have been stipulated by the parties. The stipulation of facts, the supplemental stipulation of facts, and the exhibits attached thereto are incorporated herein by this reference. Petitioner was incorporated in Oklahoma on January 24, 1964, for the purpose of engaging in the business of automobile financing. At the time its petition was filed in this Court, petitioner's principal place of business was in Lawton, Oklahoma. Petitioner reported income and expenses for Federal income tax purposes on the basis of the accrual method of accounting and used the calendar year as its taxable year.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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