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5. whether petitioner Victor I. Podd was a resident of the
United States during 1990; and
6. whether petitioners are liable for certain additions to tax
and penalties as determined by respondent.
For convenience and clarity, we have divided our opinion into
separate segments. The first segment sets forth general findings of
fact applicable to all of the issues in the instant case. Each of
the segments following our general findings of fact discusses one of
the separate issues set forth above and sets forth our findings of
fact and opinion concerning the respective issue.
I. General Findings of Fact
Some of the facts have been stipulated for trial pursuant to
Rule 91. The stipulations of facts are incorporated herein by
reference, and they are found accordingly.
At the time its petition was filed, in the instant case,
Powertex, Inc. (Powertex) was a New York corporation. Powertex's
principal corporate office was located at Rouses Point, New York.
At the time they filed their petitions in the instant case,
petitioners Victor T. and Julia Podd resided in Mount Royal, Quebec,
Canada; petitioner Stephen D. Podd resided in North Hero, Vermont;
and petitioner Victor I. Podd resided in Boca Raton, Florida.
A. Founding of Powertex
Powertex was incorporated under the laws of the state of
Vermont in 1977 by petitioner Victor T. Podd (Mr. Podd), his wife
petitioner Julia Podd (Mrs. Podd), and his brother Alexander Podd.
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