- 2 -
$1,000,8191 accuracy-related penalty under section 6662(a)2 on
petitioner for its taxable year ended June 30, 1993. The only
issue for decision is whether petitioner is liable for that
penalty. We hold that it is.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioner is a Delaware corporation with its principal
office in Ontario, Canada.
At all relevant times, petitioner, which was formed in 1986
as part of a reorganization and spinoff of Tandy Corporation, was
a holding company. At such times, petitioner owned stock in
various wholly owned foreign operating subsidiaries (petitioner’s
operating subsidiaries), including InterTAN Canada Ltd. (ITC), a
Canadian corporation, InterTAN U.K. Limited (InterTAN U.K.), and
InterTAN Europe S.A. (InterTAN Europe).
On May 22, 1990, petitioner, as guarantor, and ITC, InterTAN
U.K., and InterTAN Europe, as borrowers, entered into an agree-
ment entitled “REVOLVING CREDIT AND TERM LOAN AGREEMENT” (the
1990 bank agreement) with a syndicate of banks (bank syndicate),
as lenders. During a period of time not disclosed by the record,
1Unless otherwise noted, currency amounts are denominated in
United States dollars.
2All section references are to the Internal Revenue Code in
effect for the year at issue. All Rule references are to the Tax
Court Rules of Practice and Procedure.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011