James J. Coyle - Page 4




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          corresponding deductions.  Regal does not dispute the allowance             
          of the corresponding deductions.                                            
               (2) Whether Mr. Coyle failed to report commission income               
          from Regal for 1992 and 1993 of $21,130 and $18,816,                        
          respectively.                                                               
               (3) Whether Regal is liable for section 6663 civil fraud               
          penalties for its tax years ending March 31, 1990, 1992, 1993,              
          and 1994, of $2,138, $2,768, $2,645, and $2,705, respectively.              
               (4) Whether Mr. Coyle is liable for section 6663 civil                 
          fraud penalties for 1992 and 1993 of $7,487.25 and $3,962.25,               
          respectively.                                                               
               (5) Whether the periods of limitations for assessment of               
          underpayments of tax with respect to Regal and Mr. Coyle have               
          expired.                                                                    
               Respondent also determined the following:  Regal is not                
          entitled to claim a net operating loss (NOL) carryback of $18,995           
          to its tax year ending March 31, 1990, from the tax year ending             
          March 31, 1992; Regal is not entitled to claim an NOL                       
          carryforward of $24,048 to its tax year ending March 31, 1994;              
          Regal failed to report rental or installment sale income in its             
          tax year ending March 31, 1992, of $4,496; Regal is liable for an           
          addition to tax under section 6651(a)(1) for its tax year ending            
          March 31, 1994; Regal is not entitled to a claimed bad debt                 
          deduction for its tax year ending March 31, 1992, of $26,358;               






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