Thai V. Pham and Khuy T. Bui - Page 2

                                        - 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.                                                              


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