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Penalty
Year Deficiency Sec. 6662(a)
1991 $11,344 ---
1992 15,419 $3,151
1993 13,349 2,762
After considering the parties' concessions,1 the following issues
remain for our consideration: (1) Whether petitioners are
entitled to various deductions claimed on the Schedule F
(farming) for the years 1991, 1992, and 1993; (2) whether
petitioners are entitled to employee business expenses in excess
of $243.62 and $771.92 conceded by respondent for 1992 and 1993,
respectively; (3) whether petitioners are entitled to
contribution deductions in excess of the amounts conceded by
respondent; and (4) whether petitioners are liable for the
accuracy-related penalty attributable to negligence under section
6662(a)2 for 1992 and 1993.
FINDINGS OF FACT3
Petitioners were married and resided at Snow Hill, Maryland,
at the dates their petitions were filed in these cases, which
have been consolidated for purposes of trial and opinion. During
1 Petitioners conceded that they omitted interest income and
a State tax refund, but stated that those omissions were not
intentional. Respondent conceded certain deduction items after
petitioners provided documentation. The documentation is part of
the trial record.
2 Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the taxable years at issue,
and Rule references are to this Court’s Rules of Practice and
Procedure.
3 The parties’ stipulated facts and exhibits are
incorporated by this reference.
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Last modified: May 25, 2011