Norman E. Duquette, Inc. - Page 1

                                  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,                   

               Norman E. Duquette (an officer), for petitioner.                       
               Alan R. Peregoy, for respondent.                                       

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