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Unless otherwise indicated, all section references are to
sections of the Internal Revenue Code in effect for the years at
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.1
The stipulations of the parties, with accompanying exhibits, are
incorporated herein by this reference. At the time the petition
was filed, petitioner’s principal office was located in San
Diego, California.
I. Petitioner’s Operations
Petitioner is engaged in the business of assembling,
manufacturing, and selling furniture. The dispute in this case
relates to the depreciation of several items of equipment
(Equipment) owned by petitioner. Each item of the Equipment was
placed in service after 1986. For each year petitioner owned the
Equipment, the number of days each item of the Equipment was
physically located outside the United States exceeded the number
1 The parties stipulated various facts relating to the
equipment at issue in this case. Paragraphs 4, 7, and 10 of the
“STIPULATION OF FACTS” describe the equipment at issue in this
case. In referring to the paragraphs describing the equipment at
issue in this case, the parties mistakenly refer to paragraphs 4,
7, and 9. Paragraph 9 does not describe any equipment at issue
in this case. The references to paragraph 9 appear to be a
repeated typographic error. As such, references in the
“STIPULATION OF FACTS” to paragraph 9 will be treated as if the
references were to paragraph 10.
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Last modified: May 25, 2011