- 2 - Respondent determined the following deficiencies, additions, and penalties with respect to petitioner’s Federal income taxes: Accuracy-Related Addition to Tax Penalty TYE July 31 Deficiency Sec. 6651(a)(1) Sec. 6662(a) 1995 $3,872,347 $960,069.25 $774,469.40 1996 5,405,717 1,072,572.62 1,081,143.40 After giving effect to various concessions,2 the issues remaining for decision are: 1. Whether petitioner and Crocus International (Crocus) were engaged in a joint venture or joint ventures to conduct trade shows in the former Soviet Union (collectively, the foreign trade shows) during the last 7 months of the fiscal year ended July 31, 1995 and during the fiscal year ended July 31, 1996. Our holding that petitioner and Crocus were not engaged in any joint venture forecloses the question of how joint venture profits should be allocated between them. 2. In the alternative, whether and in what amounts petitioner is entitled to business expense deductions for the last 7 months of the fiscal year ended July 31, 1995 and for the fiscal year ended July 31, 1996, for amounts paid or payable to Crocus as compensation for its services in operating the foreign trade shows in addition to deductions already allowed petitioner 2Petitioner has conceded, among other things, its liability for additions to tax under sec. 6651(a)(1) and accuracy-related penalties under sec. 6662(a) for the taxable periods in issue on any underpayments finally determined.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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