O.S.C. & Associates, Inc. d.b.a. Olympic Screen Crafts - Page 2

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                                                  Penalty                             
               Year           Deficiency          Sec. 6662(a)                        
               1990           $130,182            $26,036                             
               1991           544,877             108,975                             
               1992           413,649             82,730                              
          Unless otherwise indicated, all section references are to the               
          Internal Revenue Code in effect for the years in issue, and all             
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.                                                                  
               The issues we must decide are as follows:                              
               1.  Whether petitioner, pursuant to section 162, is entitled           
          to deduct certain compensation payments to shareholders in                  
          amounts in excess of the amounts determined by respondent.  We              
          hold that petitioner is not so entitled.                                    
               2.  Whether petitioner, pursuant to section 6662(a), is                
          liable for accuracy-related penalties for negligence.  We hold              
          that petitioner is liable.                                                  
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          O.S.C. & Associates, Inc. d.b.a. Olympic Screen Crafts was                  
          incorporated under California law in 1982.  During the years in             
          issue, petitioner's principal place of business was in Fremont,             
          California.  Allen Blazick is petitioner's chief executive                  
          officer, Janette Blazick (Allen Blazick's wife) is petitioner's             





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