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MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge: These cases have been consolidated for
trial, briefing, and opinion. Respondent has determined
deficiencies in income tax and accuracy-related penalties as
follows:
Petitioner Year Deficiency Penalty
Kenco Restaurants, 1990 $36,664 $7,333
Inc. (Kenco) 1991 40,311 8,062
1992 23,068 4,614
K-K Restaurants, 1990 35,056 7,011
Inc. (K-K) 1991 18,962 3,792
1992 21,304 4,261
Tiffin Avenue Realty, 1990 4,772 954
Co., Inc. (Tiffin) 1992 4,124 825
Bryan Realty, Inc. 1992 174 35
(Bryan)
After concessions, the remaining issues to be determined
are: (1) Whether respondent's reallocations of deductions among
petitioners and certain other commonly controlled corporations
under section 482 were necessary to clearly reflect the income of
such corporations, and (2) whether petitioners are liable for the
accuracy-related penalties imposed pursuant to section 6662.
Unless otherwise indicated all section references are to the
Internal Revenue Code as in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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