T.C. Memo. 2000-293 UNITED STATES TAX COURT CALYPSO MUSIC INCORPORATED, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 12683-99. Filed September 20, 2000. P was incorporated by K. K is a motion picture music editor and P’s sole shareholder, director, and officer. P contracted with motion picture studios for K’s services as a music editor. Each of the contracts was memorialized, in part, by a “loan-out agreement” or a “deal memorandum”. Each contract made specific reference to the services of K. R determined P was a personal holding company as defined in sec. 542 I.R.C. for its 1996 and 1997 taxable years. R also determined that P was liable for accuracy related penalties under sec. 6662(a) I.R.C.. Held: P was a personal holding company for its taxable years of 1996 and 1997. Held, further: P in good faith and reasonably relied on the return preparers for the position taken on its returns and is not liable for penalties under sec. 6662(a) I.R.C. pursuant to sec. 6664(c) I.R.C..Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011