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1997 Federal income tax return.1 All section references are to
the Internal Revenue Code, as amended, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
Background
The parties submitted the instant case fully stipulated
without trial pursuant to Rule 122. The parties’ stipulations of
fact and the accompanying exhibits are hereby incorporated by
this reference and are found as facts in the instant case.
Petitioners resided in San Diego, California, when their petition
was filed.
On April 6, 1993, Access Anytime Anywhere, Inc. (Access),
was incorporated in the State of California. Petitioners were
the sole shareholders of Access. On May 12, 1993, Access was
renamed Navis Communications (Navis). Petitioners were the sole
shareholders of Navis. Navis was assigned a Federal Employer
Identification Number. On June 1, 2001, Navis’s corporate status
was suspended by the California Franchise Tax Board.
On November 9, 1994, Search2000 was incorporated in the
State of California. Petitioner Dale H. Sundby (Mr. Sundby) was
the president of Search2000. On September 19, 1995, Search2000
was renamed PowerAgent, Inc. Mr. Sundby was the president of
PowerAgent, Inc. The California Franchise Tax Board suspended
PowerAgent, Inc.’s corporate status on January 2, 2001. Navis
1Petitioners failed to file a brief addressing this issue.
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Last modified: May 25, 2011