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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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