Norman E. Duquette Inc. v. Commissioner
United States Tax Court
D, a consultant, carried on his consulting business as an employee of P, a "C corporation". D and his wife were the sole shareholders and directors of P. R disallowed various deductions claimed by P during its 1994 fiscal year and also determined that P was subject to the sec. 6662, I.R.C., accuracy-related penalty.
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D, a consultant, carried on his consulting business as an employee of P, a "C corporation". D and his wife were the sole shareholders and directors of P. R disallowed various deductions claimed by P during its 1994 fiscal year and also determined that P was subject to the sec. 6662, I.R.C., accuracy-related penalty. P alleged that R's notice of deficiency was invalid. 1. HELD: The notice of deficiency is valid. 2. HELD, FURTHER, R's disallowance of various deductions is sustained in substantial part. 3. HELD, FURTHER, R's penalty against P for the taxable year is sustained, in part, under…
1Opinion of the Court
NORMAN E. DUQUETTE, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Norman E. Duquette Inc. v. Commissioner
No. 1933-98
United States Tax Court
T.C. Memo 2001-3; 2001 Tax Ct. Memo LEXIS 3; 81 T.C.M. (CCH) 951; T.C.M. (RIA) 54204;
January 8, 2001, Filed
Decision will be entered under Rule 155.
D, a consultant, carried on his consulting business as an
employee of P, a "C corporation". D and his wife were the sole
shareholders and directors of P. R disallowed various deductions
claimed by P during its 1994 fiscal year and also determined
that P was subject to the sec. 6662, I.R.C.,…
2Cases cited23 opinions
- Helvering v. TaylorSupreme Court of the United States · 1935
- Commissioner v. FlowersSupreme Court of the United States · 1946
- Howard S. Scar and Ethel M. Scar v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987
- Scar v. CommissionerUnited States Tax Court · 1983
- Place v. CommissionerUnited States Tax Court · 1951
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