William Whelpley, Jr. - Page 2

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             William Whelpley, Jr., docket No. 21644-93:                               
             Addition to Tax      Penalty                                              
             Year    Deficiency       Sec. 6653        Sec. 6662                       
                 1987    $3,612        $181                 --                         
                 1989    1,148         --                   $230                       
             William and Sara Whelpley, docket No. 21690-93:                           
                                 Additions to Tax              Penalty                 
             Year   Deficiency   Sec. 6653   Sec. 6661   Sec. 6662                     
                 1987   $26,076.87   $1,304       $6,519      --                       
                 1989   22,047.87     --          --          $4,410                   

             Unless stated otherwise, all section references are to the                
             Internal Revenue Code as in effect during the years in                    
             issue.  The above-captioned cases were consolidated for                   
             trial and briefing.                                                       
                  After concessions by the parties, the issues remaining               
             for decision are:  (1) Whether certain payments made to                   
             petitioners' wholly owned S corporation are includable                    
             in petitioners' income and, if so, when the payments must                 
             be reported; (2) whether the notices of deficiency for                    
             petitioners' 1989 taxable year are valid; and, (3)                        
             whether petitioners are liable for the additions to tax                   
             and penalties determined by respondent under sections                     
             6653(a)(1)(A), 6661, and 6662(a).                                         

                                   FINDINGS OF FACT                                    
                  Some of the facts have been stipulated and are so                    
             found.  The stipulation of facts filed by the parties and                 




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