Normandie Metal Fabricators, Inc. - Page 3

                                        - 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 metal           





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011