- 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