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(2) Whether petitioner is liable for accuracy-related penalties
as determined by respondent. We hold that petitioner is liable.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. We
incorporate by this reference the stipulation of facts and the
attached exhibits. At the time of filing the petition,
petitioner had been dissolved. Petitioner’s principal place of
business had been Wilmington, Delaware.
Barbara and Walter Bandurski (Walter) founded and
incorporated petitioner in 1967. Petitioner was engaged in the
trash removal business. Petitioner was a close corporation under
Delaware law and was managed directly by its stockholders.1
Walter and Barbara were married in 1956. They both worked
for petitioner. From 1967 until 1983 or 1984, Barbara
essentially ran the office; she worked full time for petitioner
as office manager, bookkeeper, and corporate secretary. Barbara
had a good rapport with customers; in general customers preferred
dealing with her rather than Walter.
Walter and Barbara were divorced in August of 1984.
Beginning in 1983 or 1984, Barbara’s work for petitioner was less
than full time; generally she appeared for work fewer than 5 days
per week. Also in 1984, an unrelated employee replaced Barbara
1 However, petitioner was not an S corporation as defined in
sec. 1361(a).
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