Restore, Inc. - Page 2

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               After concessions, the issues for decision are:  (1) Whether           
          petitioner may accrue and deduct royalties computed but not yet             
          paid under an agreement with Matrix, a foreign corporation which            
          owns 70 percent of petitioner; (2) whether petitioner may deduct            
          interest accruals allegedly owed to Matrix on the unpaid                    
          royalties; and (3) whether petitioner is liable for accuracy-               
          related penalties pursuant to section 6662(a).1                             

                                  FINDINGS OF FACT                                    

               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the second stipulation of facts are            
          incorporated herein by this reference.                                      
               Petitioner, a Florida corporation with its principal office            
          in Fort Lauderdale, filed its Form 1120, U.S. Corporation Income            
          Tax Return, on a calendar year basis.  Petitioner reported its              
          income and kept its books using the accrual method of accounting            
          for each year in issue.  Petitioner's principal product is named            
          "Restore", an automobile engine additive sold in many stores                
          throughout the United States, Canada, and the Caribbean.  The               
          essential ingredient in the engine additive is a specially                  
          developed metal alloy (alloy) in powdered form which, when mixed            


               1Unless 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.                                                                  




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