Best Auto Sales, Inc. - Page 3




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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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Last modified: May 25, 2011