Gary L. Pierce - Page 3

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          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).                                                                 




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