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petitioner is entitled to a general business credit carryforward
for the taxable year 1989; and (2) whether petitioner is liable
for the accuracy-related penalty for negligence or disregard of
rules or regulations pursuant to section 6662(a)2 for the taxable
year 1989.
Some of the facts and issues have been stipulated and are so
found. The stipulation of facts, stipulation of settled issues,
and attached exhibits are incorporated herein by this reference.
Background
At the time petitioner filed her petition in this case, she
resided in Sacramento, California.
Petitioner was a partner in several partnerships. Two of
these partnerships (H.C. Muddox Co. and Zenith Clay Products Co.)
were related. Petitioner no longer holds interests in these
partnerships. Petitioner also held an interest in OKAL Foods, a
retail sandwich business. Petitioner no longer holds an interest
in OKAL Foods, because it has ceased operations.
2In her notice of deficiency, respondent relied on the
following alternative bases to support her imposition of the
accuracy-related penalty: (1) Negligence or disregard of rules
or regulations, (2) substantial understatement of income tax, and
(3) substantial valuation overstatement. See sec. 6662(b).
However, on brief, respondent addresses only the first of these
bases (i.e., negligence or disregard of rules or regulations).
We find that respondent has abandoned the other bases for the
accuracy-related penalty and, therefore, address only the
negligence issue.
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