T.C. Memo. 2001-3
UNITED STATES TAX COURT
NORMAN E. DUQUETTE, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1933-98. Filed January 8, 2001.
D, a consultant, carried on his consulting
business as an employee of P, a "C corporation". D and
his wife were the sole shareholders and directors of P.
R disallowed various deductions claimed by P during its
1994 fiscal year and also determined that P was subject
to the sec. 6662, I.R.C., accuracy-related penalty. P
alleged that R’s notice of deficiency was invalid.
1. Held: The notice of deficiency is valid.
2. Held, further, R’s disallowance of various
deductions is sustained in substantial part.
3. Held, further, R’s penalty against P for the
taxable year is sustained, in part, under sec. 6662,
I.R.C.
Norman E. Duquette (an officer), for petitioner.
Alan R. Peregoy, for respondent.
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