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the taxable year ended February 28, 1993?2 We hold that they
are.
(4) Are petitioners liable for the accuracy-related penalty
under section 6662(a) for each of the taxable years at issue
except the taxable year ended February 28, 1993? We hold that
they are.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioner Florida Industries Investment Corporation (FIIC)
had its principal place of business in Orlando, Florida, at the
time the petition was filed.
At all relevant times, FIIC was the common parent of an
affiliated group within the meaning of section 1504(a). That
group included, inter alia, OIP, Indian River Farms, Inc. (IRF),
and Canti Carriage Company (CCC). Throughout the taxable years
at issue, William Canty (Mr. Canty) was the sole stockholder of
FIIC, which owned 100 percent of the outstanding stock of OIP,
IRF, and CCC, and he also was the president of, inter alia, FIIC
and each of those subsidiaries of FIIC. At all relevant times,
the principal business activity of both OIP and IRF was real
estate investment and development, and the principal business
activity of CCC was auto sales.
2Although respondent made determinations with respect to
petitioners’ taxable year ended Feb. 28, 1993, those determina-
tions did not result in a deficiency, and respondent made no
determinations under secs. 6651(a)(1) and 6662(a), for that year.
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