- 3 - FINDINGS OF FACT The parties have stipulated some of the facts, which we incorporate in our findings by this reference. When he filed his petition, petitioner resided in Franklin, Tennessee. Petitioner’s Accounting Activity During the years in issue, petitioner was a certified public accountant (C.P.A.) practicing with Romer & Co., a Minneapolis, Minnesota, accounting business that he founded in 1974. As part of his accounting practice, petitioner prepared individual State and Federal income tax returns for aircraft pilots. Petitioner’s Aviation Activities During the years in issue, petitioner also engaged in various aviation activities as a licensed commercial pilot, a certified flight instructor, a licensed aircraft dealer, an airline transport pilot, and a charter pilot (the aviation activities). During the years in issue, petitioner owned, at different times, four aircraft: A Piper Navajo N1430S, a Piper Navajo N55CT, an Aero Commander N163D, and a King Air N623R (collectively, the aircraft). Petitioner used the aircraft in his aviation activities. During the subject years, petitioner had no charter certificate. In order to fly his aircraft on charter flights, 4(...continued) Court lacks jurisdiction to redetermine the sec. 6654(a) additions to tax.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