RJ Channels, Inc. v. Commissioner

T.C. Memo. 2018-27

UNITED STATES TAX COURT RJ CHANNELS, INC., ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 25151-15, 11955-16, Filed March 14, 2018. 11957-16. Walter D. Channels, for petitioners. Mindy S. Meigs, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION CHIECHI, Judge: Respondent determined a deficiency in, and an accuracy- related penalty under section 6662(a)2 on, the Federal income tax (tax) of each petitioner for the taxable year indicated, as follows: 1 Cases of the following petitioners are consolidated herewith: Channels & Channels,…