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Penalties
Year Deficiency Sec. 6662
1991 $3,009,338 $601,868
1992 1,704,166 340,833
1993 605,629 121,125
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure. After concessions by the parties, the issues we must
decide are: (1) Whether an acquisition by petitioner was made
for the principal purpose of avoiding or evading tax as defined
by section 269(a), and (2) whether petitioner is liable for
accuracy-related penalties pursuant to section 6662(a).
References to petitioner in the singular are to Plains Petroleum
Company.
FINDINGS OF FACT
Pursuant to Rule 91, some of the facts have been stipulated
for trial, which stipulations are incorporated herein by
reference and are found as facts in the instant case. When
petitioner filed the petition, its principal place of business
was located in Denver, Colorado. Petitioner is the common parent
of an affiliated group of corporations that filed consolidated
Federal income tax returns for the years in issue. Petitioners
are engaged in the oil and gas business.
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Last modified: May 25, 2011