Nicole Rose Corp., Formerly Known as Quintron Corporation v. Commissioner of Internal Revenue

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 penal ties 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 economic effects of the transfer of lease interests and the pre-tax profit earned by Rose through the disputed transactions. We affirm. 2

The dispute between the Commissioner of Internal Revenue (“Commissioner”) and…