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Following concessions by petitioner,1 the remaining issues for
decision are: (1) Whether petitioner had additional income of
$2,031,778 in its tax year ended June 30, 1991; (2) whether
petitioner is liable for the section 6651(a)(1) addition to tax;
and (3) whether petitioner is liable for the section 6662(a)
accuracy-related penalty.
All section references are to the Internal Revenue Code in
effect for the year in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The
stipulations of facts and the attached exhibits are incorporated
herein by this reference.
Cleo Perfume, Inc.
Cleo Perfume, Inc. (petitioner or CPI), a Florida corporation,
is engaged in the business of distributing perfume on a wholesale
basis. Its principal place of business at the time the petition
was filed was Miami, Florida. It employs the accrual method of
accounting and reports its income on the basis of a fiscal year
ending June 30.
1 Petitioner conceded that it is entitled to neither a
$65,000 bad debt deduction nor $59,701 in "other deductions".
Petitioner also conceded that it is liable for a $400
environmental tax.
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