- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011