- 2 - The 1980 through 1982 deficiencies are attributable solely to respondent's determination that no investment tax or business energy credits are allowable for the 1983 year, and hence, none are available to carry back to 1980 through 1982. The issues remaining for our consideration are: (1) Whether petitioners are entitled to deduct various expenses paid by checks drawn on the account of petitioner's S corporation; (2) whether $90,000 of income received by petitioner in 1982 was repaid to a related corporation during 1983, and if any amount was repaid, whether it results in a deduction for petitioners; (3) whether petitioners are liable for additions to tax for fraud under section 6653(b);1 and (4) whether the periods for assessment of income taxes had expired before the notice of deficiency was issued. FINDINGS OF FACT2 Petitioners resided in St. Petersburg, Florida, at the time their petition was filed.3 Petitioners filed joint Federal income tax returns and amended returns on the following dates: Year Original Filed Amended Filed 1980 Mar. 25, 1983 Dec. 4, 1985 1981 Mar. 25, 1983 Dec. 4, 1985 1982 Mar. 10, 1984 Dec. 4, 1985 1983 June 23, 1984 Dec. 4, 1985 1 Section references are to the Internal Revenue Code in effect for the taxable years under consideration. Rule references are to this Court's Rules of Practice and Procedure. 2 The parties' stipulation of facts and the attached exhibits are incorporated by this reference. 3 Jack R. Prewitt maintained his residence in St. Petersburg, Florida, but at the time the petition was filed, he was incarcerated in the Federal Prison Camp located on Tyndall Air Force Base, which is situated in the State of Florida.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