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KENCO RESTAURANTS, INC. v. C.I.R.

Nos. 98-2416-98-2418, and 98-2420.

206 F.3d 588 (2000)

KENCO RESTAURANTS, INC. (98-2416); K-K Restaurants, Inc. (98-2417); Tiffin Avenue Realty Company, Inc. (98-2418); Bryan Realty, Inc. (98-2420), Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided and Filed: February 16, 2000.

Attorney(s) appearing for the Case

John D. Steffan (argued and briefed), Steffan and Associates, Fairfax, VA, for Petitioner-Appellant.

Stuart L. Brown, Internal Revenue Service, Office of Chief Counsel, Teresa E. McLaughlin, Charles F. Marshall (argued and briefed), U.S. Department of Justice, Appellate Section, Tax Division, Washington, DC, for Respondent-Appellee in Nos. 98-2416, 98-2418, and 98-2420.

Teresa E. McLaughlin (briefed), Charles F. Marshall (briefed and argued), U.S. Department of Justice, Appellate Section, Tax Division, Washington, DC, for Respondent-Appellee in No. 98-2417.

Before: BOGGS and SUHRHEINRICH, Circuit Judges; POLSTER, District Judge.

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 seeking a redetermination of the deficiencies and accuracy...

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