Kenco Restaurants, Inc. v. Commissioner

OPINION

SUHRHEINRICH, Circuit Judge.

The Commissioner of the Internal Revenue Service (“Commissioner”) sent Petitioners notices of deficiency that reallocated fees Petitioners paid for management and administrative services. The notices of deficiency also imposed accuracy-related penalties. Petitioners filed separate petitions in the United States Tax Court seek ing a redetermination of the deficiencies and accuracy-related penalties.

The tax court sustained the reallocations and penalties because Petitioners failed to overcome the presumption of correctness afforded to the notices of…