Additions to Tax
Sec. Sec. Sec. Sec.
Year Deficiency 6653(a)(1)(A) 6653(a)(1)(B) 6653(a)(1) 6661
1987 $8,195 $410 1 -- $2,049
1988 5,062 -- -- 253 1,266
1 50 percent of the interest due on $7,780.
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.
Some of the issues raised by the pleadings have been
disposed of by agreement of the parties, leaving for decision:
(1) Whether petitioners are entitled to deduct travel expenses,
including expenses of maintaining a condominium for trips to
Hayward, Wisconsin, as ordinary and necessary business expenses
related to an insurance business of Sherman J. Miller; (2)
whether petitioners are entitled to deduct amounts paid as dues
to the Midland Hills Country Club of Roseville, Minnesota,
for the years at issue; (3) whether petitioners are liable for
additions to tax for negligence under sections 6653(a)(1)(A) and
(B) for 1987 and section 6653(a)(1) for 1988; and (4) whether
petitioners are liable for additions to tax for substantial
understatement of tax under section 6661 for each of the years
1987 and 1988.
FINDINGS OF FACT
Some of the facts have been stipulated and are found
accordingly.
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Last modified: May 25, 2011