Edward W. and Edith M. Arnold, et al. - Page 4

                                        - 4 -                                         
          that form, Western’s 1998 tax year ended on November 30, 1998.              
          In the March 19, 2001, letter, respondent stated that Western was           
          not an S corporation.  In a letter to Mrs. Arnold dated June 5,             
          2002, respondent noted that Western had filed an S corporation              
          return for 1999 even though respondent told petitioners before              
          they filed that return that Western did not qualify as an S                 
          corporation.  In that letter, respondent referred to two revenue            
          rulings which provide relief to some corporations which make a              
          late S corporation election or an inadvertent termination.                  
          Respondent asked petitioners to respond if they believed that               
          Western qualified under either revenue ruling.                              
               In a letter to the Taxpayer Advocate Service dated December            
          26, 2003, Mr. Arnold asserted that petitioners’ original S                  
          corporation election for Western was valid.                                 
          C.   Mr. Arnold’s Accounting and Tax Preparation Activities and             
               Pacific Controller, Inc.                                               
               On a date not stated in the record, Mr. Arnold organized               
          Pacific Controller, Inc. (Pacific), an S corporation he owned.              
          During the years in issue Pacific used Controller International,            
          Inc.’s employer identification number.  Controller International,           
          Inc., is the same entity as or the predecessor entity to Pacific.           
          The last tax return filed by Pacific was for a tax year ending              
          January 31, 1997.                                                           
               Mr. Arnold assigned to Pacific the payments he received from           
          customers for his personal accounting services.  Pacific has                





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  Next

Last modified: May 25, 2011