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NEW PHOENIX SUNRISE CORPORATION AND SUBSIDIARIES v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 23096-05.

132 T.C. No. 9

NEW PHOENIX SUNRISE CORPORATION AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Responden.

United States Tax Court.

Filed April 9, 2009.

Attorney(s) appearing for the Case

John P. Tyler, Anthony J. Rollins, and Willard N. Timm, for petitioner.

R. Scott Shieldes and Kathryn F. Patterson, for respondent.

GOEKE, Judge:

Respondent determined a deficiency of $3,355,906 in petitioner's Federal income tax for 2001 and imposed a penalty under section 6662 of $1,298,284.1 For the reasons stated herein, we uphold the determinations in the notice of deficiency and find the section 6662 penalty applicable.

FINDINGS OF FACT

Some of the facts have been stipulated, and the stipulations of fact and accompanying exhibits are incorporated...

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