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ABC Rentals of San Antonio, Inc. v. Commissioner, 142 F.3d at
1211.
FINDINGS OF FACT
This case was submitted without a trial pursuant to Rule
122. The findings of fact are set forth in ABC Rentals I and are
incorporated herein by this reference. The stipulation and
exhibits are also incorporated herein by this reference. For
convenience, we shall repeat those facts as necessary to clarify
the ensuing discussion. We also set forth below certain
supplementary findings of fact that were not set forth in our
prior opinion but which are based on the record of the instant
case and are relevant to issues decided on remand.
The individual petitioners petitioned this Court contesting
respondent's determinations of deficiencies in their Federal
income tax as follows:
ABC Rentals of San Antonio, Inc.--Docket No. 20689-91
Tax Period Ended Deficiency
5/31/87 $7,404.90
David R. Peters and Diana L. Peters--Docket No. 20690-91
Tax Period Ended Deficiency
12/31/87 $572
12/31/88 833
John P. Parsons and Melba R. Parsons--Docket No. 20691-91
Additions to Tax
Tax Period Ended Deficiency Sec. 6661
12/31/87 $11,028 $2,757
12/31/88 8,095 2,024
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Last modified: May 25, 2011