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SEVEN W. ENTERS., INC. v. COMMISSIONER

Docket Nos. 13594-08, 13595-08.

136 T.C. 539 (2011)

SEVEN W. ENTERPRISES, INC. & SUBSIDIARIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent. HIGHLAND SUPPLY CORPORATION & SUBSIDIARIES, PETITIONERS v. Commissioner of Internal Revenue, Respondent.

United States Tax Court.

Filed June 7, 2011.

Attorney(s) appearing for the Case

Patrick B. Mathis , William J. Niehoff , and Philip D. Speicher , for petitioners.

James M. Cascino , David B. Flassing , and William G. Merkle , for respondent.

FOLEY, Judge:

The issue for decision is whether petitioners are liable for section 6662(a)1 accuracy-related penalties relating to tax years ending in 2000, 2001, 2002, 2003, and 2004 (years in issue).2

FINDINGS OF FACT

The Weder family controlled two closely held businesses: Highland Supply Corporation (HSC) and Seven W. Enterprises, Inc. (7W). HSC was the parent of a group of corporations...

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