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SEVEN W. ENTERS., INC. v. COMMISSIONER

Docket Nos. 13594-08, 13595-08.

136 T.C. 539 (2011)

SEVEN W. ENTERPRISES, INC. & SUBSIDIARIES, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent. HIGHLAND SUPPLY CORPORATION & SUBSIDIARIES, PETITIONERS v. Commissioner of Internal Revenue, Respondent.

United States Tax Court.

Filed June 7, 2011.

Attorney(s) appearing for the Case

Patrick B. Mathis, William J. Niehoff, and Philip D. Speicher, for petitioners.

James M. Cascino, David B. Flassing, and William G. Merkle, for respondent.

FOLEY, Judge:

The issue for decision is whether petitioners are liable for section 6662(a)1 accuracy-related penalties relating to tax years ending in 2000, 2001, 2002, 2003, and 2004 (years in issue).2

FINDINGS OF FACT

The Weder family controlled two closely held businesses: Highland Supply Corporation (HSC) and Seven W. Enterprises, Inc. (7W). HSC was the parent of a group of corporations...

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