- 2 -
Year Deficiency Additions to Tax Penalty
Sec. Sec. Sec.
6653(a)(1)(A) 6653(a)(1)(B) 6661
1987 $91,789 $4,589 1 $22,947
Sec. Sec. Sec.
6651(a)(1) 6653(a)(1) 6661
1988 40,848 8 $2,050 10,212
Sec.
6662
1989 9 $2
1 50 percent of the interest due on $91,789.
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, unless otherwise
indicated.
After concessions, the issues remaining for our
consideration are: (1) Whether petitioners are entitled to a bad
debt deduction in the amount of $55,000; (2) whether petitioners
are entitled to Schedule E deductions for legal fees for 1987 and
1988 in the amounts of $88,199 and $37,419, respectively; (3)
whether petitioners are entitled to section 1244 stock loss
deductions for 1988 and 1989 in the amounts of $92,500 and
$96,503, respectively; (4) whether petitioners received dividend
distributions from their S corporation in 1987, 1988, and 1989 in
the amounts of $106,212, $66,423, and $48,632, respectively; (5)
whether petitioners are liable for additions to tax for 1987 and
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Last modified: May 25, 2011