James J. Lencke and Janene B. Lencke - Page 2

                                        - 2 -                                         
          Accuracy-Related Penalties - Sec. 6662(a)2                                  
          Year   Deficiency          Sec. 6662(b)(1)     Sec. 6662(b)(2)              
          1990    $14,753                   ---             $2,815                    
          1991      4,195                  $839             ---                       
          1992      3,956                   791             ---                       

               Several issues have been conceded or settled by the parties.           
          The issues presented for decision are:  (1) Whether petitioners             
          are entitled to claimed losses incurred in their model railroad             
          activity for 1990, 1991, and 1992, so as to allow the expenses in           
          excess of the income from the activity to be deducted for Federal           
          income tax purposes; (2) whether petitioners are entitled to a              
          nonbusiness bad debt deduction for 1990; (3) whether amounts                
          received by petitioner James J. Lencke as residual insurance                
          premiums and in lieu of renewal insurance commissions during 1990           
          and 1991 are subject to self-employment tax under sections 1401             
          and 1402; (4) whether petitioners are liable for an accuracy-               
          related penalty for an underpayment of tax attributable to a                
          substantial understatement for 1990; and (5) whether petitioners            
          are liable for accuracy-related penalties for negligence or                 
          disregard of rules or regulations for 1991 and 1992.                        
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are found                   
          accordingly.  The stipulation of facts and three supplemental               


          2  All section references are to the Internal Revenue Code                  
          in effect for the years in issue, and all Rule references are to            
          the Tax Court Rules of Practice and Procedure, unless otherwise             
          indicated.                                                                  




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011