Sherman J. Miller and Alice K. Miller - Page 2

                              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                                

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