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(2) Whether petitioners Indeck Energy Services, Inc., and
Subsidiaries or petitioners Michael P. and Maya Polsky are liable
for accuracy-related penalties under section 6662(a) for their
respective taxable years ended in 1994.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
Background
Some of the facts have been stipulated and are so found.
The stipulation of facts and first supplemental stipulation of
facts, together with the exhibits attached thereto, are
incorporated herein by this reference.
Petitioners Michael P. and Maya Polsky (the Polskys) resided
in Northbrook, Illinois, at the time their petition was filed.
Indeck is the common parent of an affiliated group of
corporations making a consolidated return. Indeck’s principal
office was located in Buffalo Grove, Illinois, at the time its
petition was filed.
Prior to and during the year in issue, Indeck was engaged in
the power supply business, principally through cogeneration, the
simultaneous generation of electricity and another form of useful
thermal energy, such as steam, from the same fuel source.
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