- 2 -
1991 7,372 --- 1,474
1992 9,118 --- 1,824
Respondent, in an amended answer pursuant to section 6214(a),
asserted increased deficiencies in tax and penalties as follows:
Increase in
Increase in Penalties
Year Deficiency Sec. 6662(a)
1990 $991 $198
1991 143 29
Unless otherwise indicated, all section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
On brief, petitioners conceded the following: (1) The
deficiency and addition to tax for 1988 as determined by
respondent, (2) the portion of the deficiency that represents the
per diem payments received between June and December 1992 from
petitioners’ employers, and (3) the increased deficiencies
asserted for 1990 and 1991 in respondent’s amended answer. After
these concessions, the issues remaining for decision are:
(1) Whether the per diem payments petitioners received during
1990, 1991, and a portion of 1992 constitute taxable income;
(2) if the per diem amounts are taxable income, whether
petitioners are entitled to deduct an allowance for travel
expenses incurred while away from Port Clinton, Ohio; and
(3) whether petitioners are liable for the accuracy-related
penalty for negligence or disregard of rules or regulations for
1990, 1991, and 1992.
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