- 2 - indicated, all section references are to the Internal Revenue Code in effect for the year in issue. FINDINGS OF FACT Some of the facts have been stipulated, and the stipulated facts are incorporated in our findings by this reference. Petitioner is a corporation located in Amesbury, Massachusetts, at the time that its petition was filed. Petitioner was in the business of designing, storing, and refurbishing trade show exhibits. Petitioner began its business in mid-September 1993. Tamara C. Olbres (Olbres) was the 100-percent shareholder and president of petitioner. In 1994, petitioner was a C corporation. Petitioner used the accrual method of accounting. On its Form 1120, U.S. Corporation Income Tax Return, for 1994, petitioner claimed a deduction for professional fees in the amount of $66,865. The amount deducted was based in part on an adjusting entry to accrue a professional fee in the amount of $65,000. The Form 1120 reported compensation paid to Olbres in the amount of $42,000, salary and wages expense of $6,723, and taxable income of $75,689. Petitioner’s Form 1120 was prepared and signed by George Coupounas (Coupounas), who represented himself to be a knowledgeable certified public accountant and attorney. An audit of petitioner’s Federal income tax return for 1994 was commenced in early 1997, and an inquiry was made into thePage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011