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1Respondent alternatively argues that this amount is includable in 1988.
3. whether the Bensons are entitled to deduct expenses with
respect to a ski cabin owned by the Baden Spiel Haus partnership
in the amount of $2,635 for 1994;
4. whether the Bensons are entitled to claim a deduction
for residential rental expenses in excess of the amounts allowed
by respondent;
5. whether Burton Benson is liable for fraud penalties for
the years at issue;5 or
(a) alternatively, whether the Bensons are liable for
accuracy-related penalties for the years 1989, 1990, 1993, and
1994;
6. whether Eric B. (Eric), Brad D. (Brad), and Mark D.
(Mark) Benson are liable for accuracy-related penalties as
determined;
7. whether the Bensons and/or Eric are liable for additions
to tax for failure to file a Federal income tax return pursuant
to section 6651(a)(1) as determined;
8. whether the period of limitations bars assessment of the
Bensons’ taxes reported on their 1988, 1989, 1990, 1993, and 1994
Federal tax returns;
5We use the term “fraud penalties” to include the addition
to tax for 1988 under sec. 6653(b).
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