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Background
This case was submitted fully stipulated under Rule 122.
The facts stipulated by the parties are so found. The
stipulation of facts, with accompanying exhibits, is incorporated
herein by this reference. The following is a summary of the
facts necessary for our discussion.
Principal Place of Business
At the time the petition was filed, petitioner’s principal
place of business was in Philadelphia, Pennsylvania.
History
On April 11, 1991, petitioner was organized as a
Pennsylvania professional corporation. Since its organization,
petitioner has operated as a public accounting, bookkeeping, and
tax preparation firm. That is petitioner’s only business and its
only source of income. Petitioner is an S corporation within the
meaning of section 1361(a)(1).
Joseph M. Grey
Since petitioner’s organization, Mr. Grey has been
petitioner’s sole shareholder and its president. Petitioner
rents part of Mr. Grey’s personal residence for use as an office
2(...continued)
1122(b)(3), 110 Stat. 1766 (1996 Act). Sec. 7491, which shifts
the burden of proof to the Secretary in certain other
circumstances, does not apply to employment tax disputes. Sec.
7491(a)(1).
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Last modified: May 25, 2011