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determined that the trade or business activity was that of
Omnitec Missouri (petitioner). Petitioner contends the trade or
business activity was that of Omnitec Nevada.
The business activity in question was providing technical
assistance to commercial businesses in design and development of
computer systems adaptable to a customer’s particular needs,
including computer repairs, and other services such as
development or creation of Web sites, registration services for
the listing of a Web site on various search engines, development
of bar codes for manufacturing businesses, and other related
technology services.
The individual behind these corporations was Leland V.
Lammert (Mr. Lammert). Mr. Lammert has a Ph.D. in engineering
and attended the University of Missouri, Southern Methodist
University, and California Western University. It appears that
his sole business activity was his engagement with the three
corporations described.
Of the three entities described, Omnitec Missouri, Omnitec
Nevada, and L.V. Properties, Inc., only Omnitec Nevada filed
Federal income tax returns for the fiscal years at issue.5 The
5Based on the certificates of official record offered into
evidence at trial, the return for fiscal year ending Sept. 30,
1998, was received by the IRS on June 16, 2002, and the return
for fiscal year ending Sept. 30, 1999, was received by the IRS on
June 19, 2002. Both returns are dated by the preparer, May 14,
2002.
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