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Patrick E. McGinnis, for petitioner.
Jonathan H. Sloat, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: Respondent determined deficiencies of $10,565
and $18,226 in petitioner’s personal holding company tax for 1996
and 1997, respectively. Respondent also determined accuracy-
related penalties under section 6662(a)1 of $2,113 and $3,6452
for 1996 and 1997 respectively. We must decide whether
petitioner is subject to the personal holding company tax imposed
by section 541 for its taxable years ending January 31, 1996, and
1997. Secondly, we must decide whether petitioner is liable for
the accuracy-related penalty pursuant to section 6662(a) for each
of those years.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of fact and attached exhibits are incorporated
herein by this reference. Petitioner’s principal place of
business was in the State of California when the petition was
filed.
1 Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the years in issue. Rule
references are to the Tax Court Rules of Practice and Procedure.
2 Dollar amounts are rounded to the nearest whole dollar.
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