- 2 - Respondent determined a deficiency in petitioner’s Federal income tax of $7,981 for the taxable year 2000, as well as an accuracy-related penalty under section 6662(a) in the amount of $1,596. The issues for decision are: (1) Whether petitioner was a shareholder in an S corporation during 2000 such that petitioner is required to report his pro rata share of the corporation’s income. We hold that he was. (2) Whether petitioner is liable for the accuracy-related penalty under section 6662(a). We hold that he is not. Background Some of the facts have been stipulated, and they are so found. We incorporate by reference the parties’ stipulation of facts and accompanying exhibits. At the time that the petition was filed, petitioner resided in Auburn, Washington. Petitioner first met Philip Turner (Mr. Turner) in 1993 when they both worked at Modern Manufacturing, Inc. (Modern).2 In June 1995, petitioner and Mr. Turner formed Union Machine, which they later incorporated in the State of Washington on December 21, 1995. Union Machine’s principal business was manufacturing 2 Around that time, petitioner worked as a first quality inspector and quality control officer. By trade, petitioner and Mr. Turner are machinists.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011