- 3 - (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 thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011