Gary L. Pierce - Page 2

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          Gary L. Pierce and Mary C. Pierce                                           
                                                  Penalty                             
                    Year      Deficiency           Sec. 6662(a)1                      
                    1984      $3,513                  $703                            
                    1986      71,974                14,395                            
          1987       539,914                1105,833                                  
                    1988      527,851               105,570                           
                    1989      102,323                20,465                           
               1 For taxable year 1987, the penalty pursuant to sec.                  
          6662(a) is shown in the statutory notice as both $151,729 and               
          $105,833.  The correct amount is $105,833.                                  
          Gary L. Pierce                                                              
          Penalty                                                                     
                    Year      Deficiency           Sec. 6662(a)                       
                    1991      $444,040               $88,808                          
               By reason of respondent’s concessions, the remaining issues            
          for decision are:  (1) Whether Mary Catherine Development Co.               
          (Mary Catherine), an S corporation engaged in buying and                    
          developing land for sale to residential builders, was entitled to           
          use the lower of cost or market (LCM) method, an inventory method           
          of accounting, for taxable years 1989 and 1990 to claim                     
          reductions of income for decreases in the fair market value of              
          parcels of land held for development; and (2) whether Gary L.               
          Pierce (petitioner) and Mary C. Pierce are liable for accuracy-             
          related penalties for the years 1984, 1986 through 1989, and 1991           
          pursuant to section 6662(a) for negligence or intentional                   

               1 Unless otherwise indicated, all section references are to            
          the Internal Revenue Code in effect for the taxable years in                
          issue.  All Rule references are to the Tax Court Rules of                   
          Practice and Procedure.  Dollar amounts have been rounded to the            
          nearest dollar.                                                             




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