InterTAN, Inc. - Page 2

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          $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.                                      

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