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Cordes’s) income and, if properly included in Mr. Cordes’s
income, whether that interest is income from self-employment;
3) whether CFC may properly deduct from income
repossession costs in 1994 and 1995;
4) whether any of the petitioners are liable for the
accuracy-related penalty pursuant to sec. 6662(a) for 1994 or
1995; and
5) whether CFC and Mr. Cordes are liable for the fraud
penalty pursuant to sec. 6663(a) for 1994 or 1995.
FINDINGS OF FACT
Some of the facts have been stipulated. The stipulation of
facts and the two supplemental stipulations of facts are
incorporated herein by this reference, except as specifically
noted below. At the time the petitions in these cases were
filed, ECI’s principal place of business was in Lawton, Oklahoma;
Eddy Ben and Ellen K. Cordes resided in Lawton, Oklahoma; Joseph
P. and Jean Ann Richard resided in Lawton, Oklahoma; John J. and
Sue E. Cordes resided in Austin, Texas; and Edmund J. and June J.
Cordes (the Cordeses) resided in Lawton, Oklahoma. Eddy Ben
Cordes, Jean Ann Richard, and John Cordes are the Cordeses’
children. We refer to the Cordeses together with their children
as the Cordes family.
I. Corporate Ownership
ECI was incorporated in Oklahoma in January 1963 as an
authorized dealership for Jeep-Eagle vehicles. CFC was
incorporated in January 1964 and operated mainly to finance new
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