- 3 - disregard of rules and regulations under section 6662(b)(1).2 Because we decide that Mary Catherine is not entitled to use the LCM method, various issues that would have been implicated by our decision to the contrary have been mooted. FINDINGS OF FACT Background Most of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated by this reference. When the petitions in these cases were filed, petitioners resided in Windsor, Connecticut. Petitioners filed joint Federal income tax returns for 1984, 1986, 1987, 1988, 1989, and 1990. Petitioner filed a separate Federal income tax return for 1991. Petitioner entered the real estate business in 1969 when he began renovating apartment houses. Later, petitioner changed the focus of his business to building new houses. Prior to 1986, Derekseth Corp. (Derekseth), petitioner's wholly owned C corporation, was the business vehicle used by petitioner to acquire land, subdivide the land into lots, build houses on the lots, and sell houses and lots to individuals. On November 21, 1986, Mary Catherine was incorporated under the laws of Connecticut. Petitioner has been the only 2 Respondent concedes that petitioners are not liable for a penalty for substantial understatement of income tax under sec. 6662(b)(2).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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