- 2 -
1992 37,645 -- 7,529.00
1993 48,752 -- 9,750.40
1994 12,173 -- 2,434.60
All section references are to the Internal Revenue Code in
effect during the years in issue, and all Rule references
are to the Tax Court Rules of Practice and Procedure,
unless otherwise indicated.
The issues for decision are: (1) Whether petitioner
is subject to the personal holding company tax imposed by
section 541 for the years in issue; (2) whether petitioner
incurred passive activity losses, as defined by section
469(d), in 1992 and 1993, that are disallowed as deduc-
tions in those years, as determined by respondent; and
(3) whether petitioner is liable for the accuracy-related
penalty under section 6662(a) because of a substantial
understatement of income tax for each of the years in
issue.
FINDINGS OF FACT
Petitioner, an Oklahoma corporation, maintained its
principal place of business in Lawton, Oklahoma, at the
time the instant petition was filed on its behalf.
Petitioner was incorporated on December 15, 1976, and
commenced business as of January 1, 1977. The articles
of incorporation described the purposes for which the
corporation was formed as follows:
Page: 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