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After concessions,1 we must decide whether petitioner is liable
for the accuracy-related penalty pursuant to section 6662(a)2 for
2000.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time the petition
was filed, petitioner’s principal place of business was in San
Francisco, California.
Petitioner hired Cameron & Rolling, an accounting firm, to
prepare its 2000 Federal income tax return. Petitioner’s
business grew rapidly in 2000, and Cameron & Rolling required a
substantial amount of time to review petitioner’s financial
records. Cameron & Rolling examined petitioner’s financial
records to “[clean] up the books” and ensure compliance with GAAP
and to prepare the records to file an accurate Federal income tax
return. A Cameron & Rolling accountant spoke with petitioner’s
owners about “the usage of the plane to determine if we could
fully depreciate it and deduct the expenses associated with the
plane.”
1 Petitioner conceded the deficiencies for 1999 and 2000.
2 Unless otherwise indicated, all section references are to
the Internal Revenue Code.
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Last modified: May 25, 2011