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Hafiz ($10,000) in connection with the condemnation. We hold it
may.
2. Whether MIC is liable for additions to tax for the
failure to file returns, as determined by respondent under
section 6651(a)(1). We hold it is to the extent described
herein.
3. Whether Beverly is liable for an addition to tax for the
failure to file a return, as determined by respondent under
section 6651(a)(1). We hold it is not.
4. Whether MIC is liable for the accuracy related penalties
determined by respondent under section 6662. We hold it is to
the extent described herein.
5. Whether Beverly is liable for the negligence addition to
tax determined by respondent under section 6653(a). We hold it
is not.
Unless otherwise stated, section references are to the
Internal Revenue Code in effect for the years in issue. Rule
references are to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations of fact and the exhibits submitted therewith are
incorporated herein by this reference. MIC was incorporated on
March 2, 1973, and its principal place of business was in Durand,
Michigan, when it petitioned the Court. Beverly was incorporated
on September 19, 1978, and its principal office was in St. Paul,
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