- 5 - Zeilers only to the extent necessary to comprehend the underlying context. The corporate petitioner shall be referred to as Deitsch Plastic Company, Inc., or DPC. After concessions, the issues remaining for decision are: (1) The proper tax treatment of payments made directly from Flocktex Industries, Ltd. (FIL), an Israeli corporation, to certain of petitioners, and of foreign taxes paid thereon; (2) the proper tax treatment of payments made from FIL to Deitsch Plastic Partners (DPP) and reported by certain of petitioners as their distributive shares of partnership income; and (3) the applicability of accuracy-related penalties pursuant to section 6662(a) for negligence, intentional disregard of rules or regulations, and/or substantial understatement of income tax. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulations of the parties, with accompanying exhibits, are incorporated herein by this reference. The Deitsch Family The individuals involved in these consolidated cases are all members of the Deitsch family. David Deitsch is the patriarch of the family, and Sara is his wife. Mordecai Deitsch, Joseph Deitsch, Rachel Sandman, Ella Zeiler, and Chana Pinson are the children of David Deitsch. Joshua Sandman, B. Mayer Zeiler, andPage: 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