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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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