Scuba View, Inc. is owned by Marc C, Fisher and his wife, Sylvia A Fisher. The corporation manufactures snorkel masks with built in lighting systems used for general underwater lighting. When cut on a special way, the lights flash rapidly indicating an emergency situation (business activity code number 339900). The corporation has reported positive financial and taxable incomes since inception. The company is located at 150 Reef Road, Big Sur, California 93920.The Companys employer identification number is 98-7654321, and the calendar year is used for tax purposes. The date of incorporation was March 14, 2006. Marc C Fisher (Social security number 111-11-1111) is an 80 percent shareholder and president of the company. Sylvia A. Fisher (social security: 123-45-6789) is a 20 percent shareholder and vice president of the company. Both persons devote 100 percent of their time to the corporation. Marcs compensation is $153,695 per year, and Sylvias compensation is $85,387 per year. The corporation is not a personal holding company. While the corporation is a closely held C corporation, it does not engage in activities to which the at-risk or passive activity loss limitations apply. The corporation files its tax return on the accrual method. Inventory has been consistently valued at cost under the FIFO method using the full absorption procedure. Inventory capitalization rules of Internal Revenue Code Section 263a do not apply due to the small business exception (average annual gross receipts for the three preceding taxable years do not exceed $10 million). The accounting records are computerized