- 2 - 6662(a) in the amounts of $14,495 and $79,830, respectively. The issues remaining for decision are: (1) Is petitioner entitled to deduct for the year at issue a claimed royalty expense in the amount of $1,158,084? We hold that it is not. (2) Is petitioner liable for the year at issue for the accuracy-related penalty under section 6662(a)? We hold that it is. FINDINGS OF FACT2 Some of the facts have been stipulated and are so found. Petitioner had its principal place of business in Marina del Rey, California, at the time the petition was filed. Petitioner, which was incorporated on July 1, 1988, used the accrual method of accounting for its taxable year ended January 31, 1994, the year at issue. A. Glenn Braswell (Mr. Braswell) owned all of the stock of petitioner. He also owned all of the stock of certain other corporations.3 (We shall refer to some or 1(...continued) effect for the year at issue. All Rule references are to the Tax Court Rules of Practice and Procedure. 2Unless otherwise indicated or needed for clarity, our Findings of Fact and Opinion pertain to Feb. 9, 1999, the date of the trial in this case, and not to petitioner’s taxable year ended Jan. 31, 1994, the year at issue. In this regard, the record is poorly developed as to relevant facts pertaining to the year at issue. 3Mr. Braswell’s spouse owned one share of stock in one of (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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