- 2 -
SWIFT, Judge: Respondent determined deficiencies of $11,903
and $5,003, respectively, in petitioner’s Federal income taxes
for petitioner’s tax years ending June 30, 2002 and 2003.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue.
The issue for decision is whether petitioner’s tax return
preparation and bookkeeping services are to be treated as
accounting services. If so, petitioner will be treated as a
qualified personal service corporation under section 448(d)(2)
and will be subject to the flat 35-percent tax rate set forth in
section 11(b)(2).
FINDINGS OF FACT
Most of the facts have been stipulated and are so found.
At the time the petition was filed, petitioner’s principal
place of business was located in Las Vegas, Nevada.
In 1978, Steve Rodgers (Rodgers) incorporated petitioner as
a Nevada corporation, and until his death in 2002 Rodgers owned
all of petitioner’s stock. Petitioner’s business consisted of
providing tax return preparation and bookkeeping services, which
services Rodgers and other individuals provided as petitioner’s
employees.
Over the years, Rodgers, on petitioner’s behalf, increased
the number of petitioner’s clients and the number of employees to
perform for petitioner’s clients tax return preparation and
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011