Nicholas M. Romer - Page 3




                                        - 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.                                                           




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