Investment Research Associates - Page 175




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               (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 the              






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