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Additions To Tax and Penalties1
Docket No. Year Deficiency Sec. 6651(a)(1) Sec. 6662
16948-97 FYE 5/31/92 $ 100,580 $ 25,145 $ 20,116
17705-98 FYE 5/31/93 906,913 226,728 181,383
FYE 5/31/94 1,049,839 262,460209,968
Docket No. 1372-99 addresses the same tax years challenged in
docket No. 17705-98.
Starvest U.S., Inc. (Starvest) was incorporated under the
laws of Florida in 1987. Jacques de Bruijn served as president,
secretary, and treasurer of Starvest at its inception, and the
directors were Jacques de Bruijn and Mario Boon. Starvest
adopted a fiscal tax year ending on May 31 of each year.
On November 6, 1995, Jacques de Bruijn, as president of
Starvest, signed a power of attorney (Internal Revenue Service
(IRS) Form 2848) authorizing Allen Swartz, C.P.A., to represent
Starvest before the IRS for its tax years ending May 31, 1992,
1993, and 1994. These are the years before the Court in this
litigation.
On April 30, 1996, Starvest elected new officers and
directors. Mario Boon was elected to the offices of president,
secretary, and treasurer. Mario Boon, Willem van Weert, and
Maria Verstraeten were elected as directors of Starvest.
1 Unless otherwise indicated, section references
hereafter are to the Internal Revenue Code in effect for the
years at issue. All Rule references are to the Tax Court Rules
of Practice and Procedure.
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Last modified: May 25, 2011