- 2 - Richard J. Sapinski and Robert J. Alter, for petitioners. Robert A. Baxter, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION HALPERN, Judge: Respondent determined deficiencies in income tax and additions to tax as follows: Additions to Tax and Penalties Sec. Sec. Sec. Year Deficiency 6651(a) 6661 6662(a) 1987 $88,837 --- $39,264 --- 1988 62,391 --- 13,020 --- 1989 58,838 $22,260 --- $11,768 1990 51,762 --- --- 10,352 After concessions, the issues remaining for decision are (1) whether petitioners are allowed depreciation deductions with regard to certain "exotic automobiles" owned and exhibited by petitioner husband, (2) whether Exotic Bodies, Inc., an S corporation within the meaning of section 1361(a)(1), was engaged in a trade or business such that petitioners may claim certain losses from that corporation, (3) the basis of certain shares of stock in BSG Corp., and (4) petitioners' liability for the additions to tax under section 6661 and penalties under section 6662(a) set forth above. In their opening brief, petitioners proposed no findings of fact or made any argument with regard to the basis of any shares in BSG Corp. In her opening brief, respondent argued that, sincePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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