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Following concessions on brief,1 we must decide:
1. Whether petitioners failed to include certain business
receipts in their 1990 and 1991 gross income. We hold they did
to the extent described herein.
2. Whether petitioners failed to report $3,553 of interest
income for 1991.2 We hold they did.
3. Whether petitioners are liable for penalties on their
1990 and 1991 taxes under section 6662(a). We hold they are.
Unless otherwise indicated, section references are to the
Internal Revenue Code applicable to the years in issue. Rule
references are to the Tax Court Rules of Practice and Procedure.
Dollar amounts are rounded to the nearest dollar.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations and exhibits attached thereto are incorporated
herein by this reference. Petitioners are husband and wife, and
they filed joint Federal income tax returns for the subject
years. They resided in Hillsborough, California, when they
petitioned the Court.
1 Petitioners concede respondent's disallowance of $2,600 of
car and truck expenses and $2,295 of employee benefit program
expenses.
2 Respondent determined that petitioners failed to report
$7,463 of interest income for 1991. Petitioners concede $3,910
of this determination.
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