Transupport, Incorporated v. Commissioner of IRS

LYNCH, Circuit Judge.

Transupport, Inc. appeals from the Tax Court's decision upholding the Commissioner's notice of deficiency, which, for tax years 2006 through 2008, reduced Transupport's cost of goods sold, reduced deductions it took for compensation paid to four employee-shareholders, and assessed a 20% accuracy-related penalty. See Transupport, Inc. v. Comm'r ( Transupport II ), 112 T.C.M (CCH) 580 , 2016 WL 6900913 (2016). This is the Tax Court's second opinion in this case. The first addressed whether Transupport committed fraud. See Transupport, Inc. v. Comm'r ( Transupport I ), 110…