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.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