- 4 - indebtedness owed by Cox Tomato to them (hereinafter referred to, in the aggregate, as basis in Cox Tomato) to deduct their respective shares of the ordinary losses generated by Cox Tomato during the years at issue; (2) whether Deborah may reduce the gross income she derived from her use of a corporate automobile to reflect that she used the automobile, in part, for business and that she reimbursed Cox Tomato for some of her personal use; and (3) whether Christopher and Brenda and Gregory and Linda are liable for the accuracy-related penalty imposed by section 6662(a) for 1994, and whether Robert and Deborah are liable for the accuracy-related penalty imposed by section 6662(a) for 1995. FINDINGS OF FACT I. Background Some of the facts have been stipulated and are so found. We incorporate the stipulation of facts into these findings by this reference. On the date the petitions were filed, Christopher and Brenda resided in Edmond, Oklahoma; Gregory and Linda resided in Oklahoma City, Oklahoma; and Robert and Deborah resided in Ardmore, Oklahoma. Christopher, Gregory, and Deborah (collectively referred to as petitioner shareholders) are siblings.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