- 3 - Third, did the Lenzens have unreported gambling losses offsetting their unreported gambling income in 1999? We hold that they did not. Fourth, are petitioners liable for accuracy-related penalties under section 6662? We hold that they are. FINDINGS OF FACT Some of the facts are stipulated. The stipulation of facts, supplemental stipulation of facts, and attached exhibits are incorporated herein by this reference. At the time the petition was filed, the Lenzens resided in Prior Lake, Minnesota, and RAF’s principal place of business was in Le Center, Minnesota. In 1991, Mr. Lenzen and James A. Schoenecker incorporated RAF under Minnesota law. RAF produced a variety of gourmet desserts, specializing in cheesecakes, marketed under the trade name “Lady Dianne’s Desserts”. RAF’s products were produced in a plant in Le Center, Minnesota, and were marketed in several regions of the country by sales representatives to grocery stores, restaurants, and other food distributors. In 1999, Mr. Lenzen and Mr. Schoenecker were the only two officers and directors of RAF. Mr. Lenzen owned 59.5 percent of RAF’s stock and Mr. Schoenecker owned 25.5 percent of RAF’s stock in 1999. In addition, Steven Lenzen and David Lenzen, the Lenzens’ two sons, and Steven Countryman were employees and 5-percent shareholders of RAF in 1999. RAF issued only common stock. InPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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