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Corp., Omnitec, Inc., and L.V. Properties, Inc., constitute the
income and expenses of petitioner (identified and referred to
herein as Omnitec Missouri);3 (2) whether the income attributed to
petitioner was properly determined under the bank deposits
analysis method; and (3) whether petitioner is liable for the
additions to tax under sections 6651(a)(1) and 6655.
Background
Some of the facts were stipulated and are so found. The
stipulation of facts and accompanying exhibits are incorporated
herein by reference. Petitioner was domiciled at St. Louis,
Missouri, at the time the petition was filed.
Petitioner is a corporation that was organized in the State
of Missouri on December 15, 1980, under the name Orion
Laboratories, Inc. The name was changed in 1985 to Omnitec Corp.
The corporation was administratively dissolved by the State of
3At the outset, it is necessary to clarify and distinguish
between the taxpayers in this case. There are two corporations
that bear an identical name: Omnitec Corp. One corporation was
organized under the laws of Missouri, and the other corporation
was organized under the laws of Nevada. The corporations,
therefore, are referred to in this opinion, respectively, as
“Omnitec Missouri” and “Omnitec Nevada”. The notice of
deficiency was issued to Omnitec Missouri based on respondent’s
determination that the trade or business activity conducted in
the name of “Omnitec Corp.” was in truth and in fact the business
of Omnitec Missouri, a determination challenged by Omnitec
Missouri.
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