- 25 - (38) whether IRA is liable for the section 6653(a) additions to tax for 1980, and 1982 through 1988; (39) whether IRA is liable for the section 6659(a) additions to tax for 1982 and 1983; (40) whether IRA is liable for the section 6661 additions to tax for 1983 through 1988; and (41) whether IRA is liable for the section 6662(a) accuracy-related penalty for 1989. For convenience and clarity, the Court's findings of fact and opinion are set forth under each issue. The findings of fact with respect to any issue incorporate by this reference the findings of fact as found in any preceding issue. Issue 1. Whether Payments Made By the Five in the Prudential, Travelers, and Kanter Transactions During the Years at Issue Are Properly Taxable to Kanter, Ballard, and Lisle, and, if so, whether they are liable for the fraud additions to tax and penalty with respect to such income FINDINGS OF FACT The parties have filed several stipulations of fact. The facts reflected in these stipulations, with the annexed exhibits, are so found and are incorporated herein by reference. I. Background A. Petitioners' Residences and Principal Place of Business At the time the petitions were filed, the principal place of business of Investment Research Associates, Ltd. (IRA), was in the State of Illinois, the Kanters' legal residence was in thePage: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
Last modified: May 25, 2011