- 2 -2
1991 61,687 15,422 12,337
1992 98,291 24,573 19,658
1993 175,247 43,811 35,049
After concessions, the issues for decision are:
1. Whether respondent's determinations are entitled to the
presumption of correctness. We hold that they are.
2. Whether petitioners demonstrated that respondent's
determinations were erroneous. We hold that they did to the
extent provided below.
3. Whether petitioners are liable for additions to tax for
failure to file their tax returns in a timely manner. We hold
that they are.
4. Whether petitioners are liable for accuracy-related
penalties for substantial understatements. We hold that they are
to the extent provided below.
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.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Robert and Gerri Smith resided in Felton, Delaware, at the time
they filed their petition. At all relevant times, petitioners
owned and operated: Guns & Goodies, a retail sporting goods
store located in Dover, Delaware, and National Distributors, an
ammunition wholesale business. Mrs. Smith managed Guns &
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