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(3) Whether petitioners are liable for accuracy-related
penalties under section 6662(a).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time the petitions were filed, the principal place of
business for each petitioner was located in Tampa, Florida.
During the years in issue, petitioners owned and operated
separate used automobile dealerships. Petitioners were engaged
in the sale of used automobiles to high credit risk purchasers
and in financing the purchase of the automobiles at high interest
rates (e.g., 32 percent) over short repayment periods (e.g., 1 to
2 years). Typically, under the automobile loans that petitioners
made, the purchasers (hereafter “debtors”) of the automobiles
were obligated to make installment payments to petitioners on a
weekly, biweekly, semimonthly, or monthly basis.
When loan payments due on petitioners’ automobile loans
became delinquent, petitioners’ office personnel mailed to the
debtors past due notices and demand letters requesting that the
delinquent amounts due on the loans be paid.
If the debtors failed to make the delinquent payments due on
the automobile loans within a few days or weeks after
notification, petitioners initiated repossession of the debtors’
automobiles through a third-party automobile repossession agent.
After repossession of the automobiles, petitioners notified the
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