Nicole Rose Corp., formerly Quintron Corporation - Page 2




                                        - 2 -                                         
               SWIFT, Judge:  For petitioner’s taxable years ending                   
          January 31, 1992, 1993, and 1994, respondent determined                     
          deficiencies in petitioner’s Federal income taxes and accuracy-             
          related penalties as follows:                                               

                                          Accuracy-Related Penalty                    
                 Year    Deficiency       Sec. 6662(a)                                
                 1992    $1,171,365               $234,273                            
                 1993    684,700                  136,940                             
                 1994    4,559,237                911,847                             

               Unless otherwise indicated, 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.                                                                  
               The primary issue for decision is whether the transfer of              
          petitioner’s interests in multilayered leases of computer                   
          equipment and related trusts had business purpose and economic              
          substance and should be recognized for Federal income tax                   
          purposes and whether petitioner should be entitled to the                   
          $22 million in claimed ordinary business expense deductions                 
          relating thereto.                                                           

                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
               At the time the petition was filed, petitioner’s principal             
          place of business was located in Jericho, New York.                         







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Last modified: May 25, 2011