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World of Service, Inc.--Docket No. 4338-87
Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6653(a)(1) 6653(a)(2) 6661
1982 $21,848 $1,092 1 $5,462
1983 79,134 3,957 1 19,784
1984 88,404 4,420 1 22,101
1 50 percent of the interest due on the deficiency.
Feelin' Great, Inc.--Docket No. 4341-87
Additions to Tax
Sec. Sec. Sec.
FYE Deficiency 6653(a)(1) 6653(a)(2) 6661
1983 $160,895 $8,045 1 $40,224
1984 74,039 3,702 1 18,010
1 50 percent of the interest due on the deficiency.
After the parties' concessions, the issues remaining for our
consideration are: (1) Whether petitioners have shown that they
are entitled to various deductions in excess of the amounts
allowed by respondent; and (2) whether petitioners are liable for
additions to tax under sections 6653(a)(1) and (2) and 6661.1
FINDINGS OF FACT2
Petitioners, World of Service, Inc. (Service), and Feelin'
Great, Inc. (Great), are Florida corporations, and Chris H.
Johnson (Mr. Johnson) was president of each corporation at all
relevant times. At all relevant times, Mr. Johnson and his wife,
1 Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the years in issue. Rule
references are to this Court's Rules of Practice and Procedure.
2 The parties' stipulation of facts and exhibits are
incorporated by this reference.
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