- 2 - SWIFT, Judge: Respondent determined a deficiency in, an addition to tax on, and an accuracy-related penalty on petitioners' 1990 joint Federal income tax as follows: Accuracy-Related Addition to Tax Penalty Deficiency Sec. 6651(a)(1) Sec. 6662(a) $423,531 $101,585 $84,706 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for 1990, and all Rule references are to the Tax Court Rules of Practice and Procedure. All references to petitioner are to Robert A. Stanford. The issues for decision are whether subpart F income of a controlled foreign corporation may be reduced by deficits in earnings and profits of a controlled foreign sister corporation and whether subpart F income of a controlled foreign corporation may be reduced by deficits in earnings and profits of a controlled foreign parent corporation. FINDINGS OF FACT Many of the facts have been stipulated and are so found. During the year in issue, petitioners were U.S. citizens and resided in Houston, Texas. In the mid-1980's, favorable laws in the crown colony of Montserrat, British West Indies, made it relatively easy and profitable for individuals to establish and to operate privatePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011