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(1) Whether, and if so then to what extent, petitioner
understated its gross income (gross receipts less cost of
goods sold) from the sale of diesel fuel;
(2) Whether, and if so then to what extent, petitioner
is entitled to claimed section 162 deductions for certain
expenses; and
(3) Whether, and if so then in what amount, petitioner
is liable for an accuracy-related penalty under section
6662(a).
FINDINGS OF FACT
Some of the facts have been stipulated; the stipulations and
the stipulated exhibits are incorporated herein by this
reference.
At the time the petition was filed, petitioner was a
corporation with its principal place of business in Le Grand,
California.
1. Background
During petitioner’s fiscal year ending June 30, 1990
(hereinafter sometimes referred to as petitioner’s fiscal 1990):
petitioner was a C corporation; Serop Khachatourian, also known
as Steve Khachatourian (hereinafter sometimes referred to as
Steve), and Andranik Khachatourian, also known as Andy
Khachatourian (hereinafter sometimes referred to as Andy),
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Last modified: May 25, 2011