- 3 - 1994, and $445,000 in 1995, based on the following amounts of reasonable compensation: Year Isidore Klein Steven Klein Total 1993 $200,000 $300,000 $500,000 1994 200,000 300,000 500,000 1995 5,000 440,000 445,000 2. Whether petitioner is liable for the accuracy-related penalty under section 6662 for substantial understatement of tax for 1993, 1994, and 1995. We hold that it is for 1993 and 1994, but not for 1995. Section references are to the Internal Revenue Code in effect during the years in issue. Rule references are to the Tax Court Rules of Practice and Procedure. I. FINDINGS OF FACT Some of the facts have been stipulated and are so found. Petitioner is a corporation the principal office of which was in Port Washington, New York, when it filed the petition. A. The Kleins Isidore Klein was born in 1913. He is married to Gertrude Klein. He was a baker and taught baking at a vocational high school in New York. He also manufactured small metal products that he used in his baking business. Steven Klein was born in 1942. He is the son of Isidore and Gertrude Klein. B. Formation of Petitioner Petitioner manufactures and sells small implements and metalPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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