- 2 -
Additions to Tax and Penalty
Year Deficiency Sec. 6653(a) Sec. 6661 Sec. 6662
1988 $36,888 $1,844 $9,222 -
1989 10,613 - - $2,123
After concessions, the issues for our consideration are:
(1) Whether petitioners are entitled to Schedule C
deductions for the cost of labor in excess of the amounts allowed
by respondent for taxable years 1988 and 1989. We hold that they
are not.
(2) Whether petitioners are entitled to a Schedule C
equipment rental deduction in the amount of $7,200 for taxable
year 1988. We hold that they are not.
(3) Whether petitioners received unreported income of
$14,000 during taxable year 1988. We hold that they did.
(4) Whether petitioners are liable for the addition to tax
pursuant to section 6653(a)1 for the underpayment of tax due to
negligence or intentional disregard of the rules or regulations
for taxable year 1988. We hold that they are.
(5) Whether petitioners are liable for the addition to tax
pursuant to section 6661(a) for a substantial understatement of
income tax for taxable year 1988. We hold that they are.
(6) Whether petitioners are liable for the accuracy-related
penalty pursuant to section 6662 for taxable year 1989. We hold
that they are.
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect during the years in issue,
and all Rule references are to the Tax Court Rules of Practice
and Procedure.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011