- 2 - Accuracy-Related Fiscal Year Ended Deficiency Penalty Sec. 6662(a) March 31, 1991 $8,500 $1,700 March 31, 1992 34,000 6,800 Unless otherwise noted, all section references are to the Internal Revenue Code in effect for the years in issue. We must decide the following issues: (1) Whether there was a valid covenant not to compete between petitioner and Thomas Wagner, entitling petitioner to amortization deductions for the cost of the covenant. We hold that there was a valid covenant not to compete and that petitioner is entitled to amortization deductions. (2) Whether petitioner is liable for the accuracy-related penalties as determined by respondent. We hold that petitioner is not liable. FINDINGS OF FACT Some of the facts have been stipulated and are so found. We incorporate by this reference the stipulation of facts, first supplemental stipulation of facts, and attached exhibits.1 At the time of filing the petition, petitioner was incorporated under the laws of Delaware with its principal place of business in Houston, Texas. 1 At trial, respondent withdrew hearsay objections to several of the exhibits attached to the stipulations.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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