- 2 - OPINION FOLEY, Judge: By notice dated September 27, 1995, respondent determined deficiencies in petitioner's Federal income taxes as follows: Year Deficiency 1992 $10,443 1993 1,828 Unless 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. The issue for decision is whether petitioner, pursuant to section 7872, has interest income from loans it made to its shareholders. We hold that it does. Background The facts have been fully stipulated under Rule 122 and are so found. At the time the petition was filed, petitioner's principal place of business was in Pittsburgh, Pennsylvania. During the years in issue, petitioner provided various services within the coatings industry, including consulting, engineering, inspection, and lab analysis. Kenneth B. Tator is the president of petitioner, and he and his wife (the Tators) are its sole shareholders. In 1991, the Tators began two construction projects. The first project involved the expansion of petitioner's PittsburghPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011