Nick Kikalos and Helen Kikalos - Page 2

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          $21,059.20.  After concessions,2 the issues presented for our               
          consideration are:  (1) Whether petitioners’ income was                     
          understated and (2) whether petitioners are subject to section              
          6662(a) penalties for substantial understatement of tax or                  
          negligent disregard of the rules or regulations.                            
                                  FINDINGS OF FACT3                                   
               Petitioners Nick Kikalos and Helen Kikalos resided in                  
          Hammond, Indiana, at the time their petition was filed.  In the             
          statutory notice of deficiency, respondent determined that                  
          petitioners had unreported income from the following sources:               
          (1) Coupon and buy-down reimbursement payments from tobacco                 
          companies; (2) rack and promotional payments; (3) vendor refunds            
          and reimbursements; and (4) insurance recovery payments.                    
               During 1997, Nick Kikalos4 (petitioner) owned and operated             
          four retail stores under the name of Nick’s Liquor Mart (Nick’s             
          Liquors) in Hammond, Indiana, selling cigarettes, beer, liquor,             
          wine, and other products.  During the year at issue, cigarette              
          manufacturers employed “buy-down” programs to lower the cost of             
          cigarettes at which retailers, including Nick’s Liquors, sold to            

               2 Respondent conceded $23,244 of the $224,620 gross receipts           
          adjustment, as well as an adjustment of $19,652 with respect to             
          unreported income from H&L Display Co.                                      
               3 The parties’ stipulation of facts is incorporated by this            
          reference.                                                                  
               4 Petitioner Helen Kikalos is a party to this case by reason           
          of the fact that she filed a joint Federal income tax return with           
          Nick Kikalos for the year under consideration.                              




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