-3- discussion. The stipulation and exhibits are also incorporated herein by this reference. Leonard Pipeline Contractors, Ltd., petitioned this Court contesting respondent’s determination of an $807,983 deficiency in its Federal income tax for its taxable year ended September 30, 1987, and additions to tax pursuant to section 6653(a)(1)(A) in the amount of $40,399 and section 6653(a)(1)(B) in the amount of 50 percent of the interest on $807,983. The deficiency was based on respondent's determination that $1,642,593 of the $1,777,800 petitioner deducted as compensation paid to Richard L. Leonard was unreasonable. Respondent subsequently conceded the additions to tax. At the time petitioner Leonard Pipeline Contractors, Ltd., filed its petition herein, its principal place of business was in Scottsdale, Arizona. Petitioner filed the relevant Federal income tax return based on a fiscal year ended September 30, 1987. (All references hereinafter to petitioner's relevant years refer to petitioner's fiscal years ended September 30.) Richard L. Leonard had extensive experience in the pipeline industry, dating from the 1950's. In 1977, he caused petitioner to be established in Canada and became its president and chief financial and operating officer. At all relevant times, petitioner's stock was wholly owned by R.L. Leonard Holdings, Ltd. (RLLH), whose stock in turn was wholly owned by Mr. Leonard. Petitioner became a U.S. corporation on April 18, 1985.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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