- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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