-8- Aurora Elsa Arnaiz (Arnaiz) is the sister of Rosas. She is a citizen and resident of Mexico. On June 1, 1992, petitioner issued additional shares of its stock to Arnaiz. Afterwards, Arnaiz owned 52 percent of petitioner’s stock, and Rosas owned the remaining 48 percent. III. Petitioner’s Initial Tax Return On September 14, 1992, petitioner filed a Form 1120-F with respondent’s service center in Philadelphia, Pennsylvania (Philadelphia Service Center), for its short taxable year from June 27, 1991, through May 31, 1992 (1992 taxable year). The return (petitioner’s initial return) was petitioner’s first Federal income tax return. That return was prepared by Francisco A.F. Cervantes (Cervantes), petitioner’s tax adviser and certified public accountant in California. As to petitioner’s 1992 taxable year, petitioner’s initial return reported that petitioner had no income or expense, that it had not engaged in a trade or business in the United States, and that it had no effectively connected income. Petitioner’s initial return also reported that petitioner’s business activity was real estate and that its product or service was investment. Petitioner’s initial return also reported that petitioner was incorporated in Barbados and that petitioner was subject to income tax under the laws of Barbados.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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