Don C. Reser and Rebecca Jo Reser - Page 2

                                          2                                            
          Tax Court Rules of Practice and Procedure, except as otherwise               
          noted.                                                                       
               Petitioners have conceded that they are liable for a 10-                
          percent early distribution penalty applied to a $28,000                      
          distribution from an individual retirement account during 1987.              
          The remaining issues for our decision are:                                   
               (1) Did petitioners have sufficient basis in Don C. Reser,              
          P.C., a solely owned subchapter S corporation, to claim                      
          distributive losses greater than the amount allowed by                       
          respondent?  We hold that they did not.                                      
               (2) Is petitioner husband liable for self-employment tax due            
          on $15,000 of income which was earned by petitioner wife during              
          1987?  We hold that he is not.                                               
               (3) Are petitioners liable for an addition to tax under                 
          section 6651(a) for failure to timely file an income tax return              
          for 1987?  We hold that they are.                                            
               (4) Are petitioners liable for additions to tax under                   
          section 6653(a)(1) and section 6653(a)(1)(A) and (B) for the                 
          intentional or negligent disregard of rules and regulations in               
          filing their 1987 and 1988 income tax returns?  We hold that they            
          are.                                                                         
               (5) Are petitioners liable for additions to tax under                   
          section 6661 for 1987 and 1988 for substantial understatement of             
          taxes?  We hold that they are.                                               






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