Alan D. Lenzen and Dianne Lenzen - Page 3

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               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.  In             






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