- 2 - 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'sPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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