- 7 -
(5) whether Menards and Mr. Menard are liable for accuracy-
related penalties under section 6662(a) for negligence or
disregard of rules or regulations.
FINDINGS OF FACT
Some of the facts have been stipulated. We incorporate the
stipulated facts into our findings by this reference.4 Both
4In the stipulation of facts, petitioners objected on the
basis of relevance to stipulations concerning Menards’s officers’
compensation for TYE 1999, TMI’s involvement in the NASCAR
Craftsman Truck Series in 2000, and Menards’s sponsorship of a
Championship Auto Racing Team (CART) driver in 1999. We sustain
petitioners’ objections.
In addition, in the stipulation of facts, both parties
objected to the admission of several accompanying exhibits on the
basis of relevance. Petitioners objected to the admission of
Exhibit 36-J, TMI’s 1999 income tax return; Exhibits 61-J through
64-J, documents pertaining to Menards’s revolving credit program;
Exhibit 65-J, a 1995-96 Indy Racing League season associate-
sponsorship agreement between TMI and Green Tree Financial Corp.;
and Exhibit 66-J, documents pertaining to Menards’s business
relationship with Stanley Tools, including mention of Stanley
Tools as a TMI associate sponsor. We sustain petitioners’
objections.
Respondent objected on the basis of relevance to the
admission of Exhibit 17-J, to the extent that it analyzes
Menards’s officer compensation in years before 1991; Exhibit 75-
J, drawings currently used to promote Menards’s Race to Savings
sale; Exhibits 78-J and 79-J, 1993 and 1997 Internal Revenue
Service Information Document Requests addressed to Menards;
Exhibits 80-J and 81-J, Income Tax Examination Changes for
Menards’s TYE 1991, TYE 1992, and TYE 1994 through TYE 1997;
Exhibits 83-J through 92-J, independent auditor’s reports for
Menards’s TYE 1972 through TYE 1991; Exhibit 106-J, to the extent
it includes diagrams of Menards’s store prototypes other than
Prototype III; Exhibit 107-J, a memo to Glidden from Menards;
Exhibits 123-J through 127-J and 129-J, magazine and online news
articles about racing, printed in 1999, 2000, and 2001; and
Exhibit 128-J, a complaint filed in an unrelated case in 2000 for
(continued...)
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