NICOLE ROSE CORP. v. C.I.R.

Docket No. 02-4110.

320 F.3d 282 (2002)

NICOLE ROSE CORP., formerly known as Quintron Corporation, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Second Circuit.

Decided December 13, 2002.

Publication Ordered: February 24, 2003.


Attorney(s) appearing for the Case

Robert F. Denvir, Winston & Strawn (James M. Lynch, Peter W. Poulos, David L. Theyssen, on the brief), Chicago, IL, for Petitioner-Appellant.

Thomas J. Sawyer, Tax Division, Department of Justice (Eileen J. O'Connor, Assistant Attorney General, Teresa E. McLaughlin, on the brief), Washington, DC, for Respondent-Appellee.

Before: WALKER, Chief Judge, OAKES and CARDAMONE, Circuit Judges.


PER CURIAM.

Petitioner-appellant Nicole Rose Corp.1 ("Rose") appeals from the December 28, 2001 decision of the United States Tax Court finding deficiencies of $1,171,365, $684,700, and $4,559,237 for 1992, 1993, and 1994, respectively and imposing penalties totaling $1,283,060, pursuant to 26 U.S.C. § 6662(a). On appeal, Rose argues that the tax court erred because it disregarded the real...

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