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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, and
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