Metro Leasing and Development Corporation - Page 2




                                        - 2 -                                         
                            Deficiencies                                              
                         Income    Accumulated      Penalty                           
                Year     tax      earnings tax   sec. 6662(a)                         
               1995      $307,699    $108,714     $61,540                             
          1996           142,559       ---        28,512                              
          The parties have reached agreement with respect to several                  
          issues, and the following issues remain for our consideration:              
          (1) Whether for its 1995 or 1996 tax year petitioner is entitled            
          to deduct officer’s compensation in any amount exceeding $76,800,           
          the amount determined by respondent; (2) whether for its 1995 tax           
          year petitioner permitted its earnings to accumulate beyond the             
          reasonable needs of the business so as to be subject to the                 
          accumulated earnings tax; and (3) whether petitioner is liable              
          for an accuracy-related penalty under section 6662(a)2 for 1995             
          and/or 1996.                                                                
                                  FINDINGS OF FACT                                    
               Metro Leasing and Development Corp., petitioner, had its               
          principal place of business in El Macero, California, at the time           
          the petitions were filed in these cases.  During the years in               
          issue, George Valente, who was approximately 70 years old, was              
          director and owned 100 percent of the common stock of petitioner.           
          Mr. Valente became ill in 1992 and suffered from prostate cancer            
          during 1995 and 1996.  Mr. Valente was somewhat disabled by and             


               2 All section references are to the Internal Revenue Code in           
          effect for the years in issue, and all Rule references are to the           
          Tax Court Rules of Practice and Procedure, unless otherwise                 
          indicated.                                                                  




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