AMW Investments, Inc. - Page 2

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          Taxable Year                  Additions to Tax      Penalty                 
          Ended                         Sec.      Sec.      Sec.                      
          August 31  Deficiencies       6651(a)(1)   6653(a)     6662                 
          1989          $656            $164      $6,615       ---                    
          1990        20,000            5,000     ---     $4,000                      
          1991        36,133            9,033     ---            7,227                
          Following concessions, we must decide:                                      
               1.  Whether petitioner’s payments to an escrow account (the            
          Fund) are deductible as ordinary and necessary business expenses.           
          We hold they are not.                                                       
               2.  Whether petitioner’s payments to its sole shareholder              
          are deductible as interest.  We hold they are not.                          
               3.  Whether petitioner is liable for the additions to tax              
          for delinquency determined by respondent under section                      
          6651(a)(1).  We hold it is.                                                 
               4.  Whether petitioner is liable for the addition to tax for           
          negligence or intentional disregard of rules or regulations                 
          determined by respondent under section 6653(a).  We hold it is.             
               5.  Whether petitioner is liable for the accuracy-related              
          penalties for negligence or intentional disregard of rules or               
          regulations determined by respondent under section 6662.  We hold           
          it is.                                                                      
               Unless otherwise stated, section references are to the                 
          Internal Revenue Code in effect for the years in issue.  Rule               
          references are to the Tax Court Rules of Practice and Procedure.            
          Dollar amounts are rounded to the nearest dollar.  We refer to              
          Harry V. Mohney as Mr. Mohney.  We refer to petitioner’s taxable            



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