- 2 - Year Deficiency Penalty 1991 $209,006 $41,801 1992 192,075 38,415 1993 204,804 40,961 After concessions, the issues for consideration are: (1) Whether the royalties paid to Dharma Mudranalaya for certain intangible assets were reasonable in amount, (2) whether petitioner is entitled to deduct net operating loss carryovers in taxable years 1991 and 1993, (3) whether petitioner must increase gross sales by $7,095 in taxable year 1992, and (4) whether petitioner is liable for a section 6662(a) accuracy-related penalty for each of the years in issue. FINDINGS OF FACT Petitioner had its principal place of business in Oakland, California, at the time the petition in this case was filed. Petitioner operates a sheet-fed, lithographic commercial printing business and provides typesetting, prepress, printing, and binding services. Petitioner also prints religious calendars, postcards, and greeting cards through its Amber Lotus division. Petitioner claimed deductions under section 162(a) for the payments to Dharma Mudranalaya (DM), a related entity, pursuant to a license agreement for certain intangible assets in taxable years ending May 31 as follows: Year Deduction Claimed 1989 $648,000 1990 785,000 1991 680,817 1992 854,840 1993 788,189Page: 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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