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Taxable
Year Addition to Tax Penalty
Ended Sec. Sec.
May 31 Deficiencies 6651(a)(1) 6662
1990 $2,687 $672 $537
1991 14,677 --- 2,935
1992 16,546 --- 3,309
Following concessions, we must decide:
1. Whether funds advanced by petitioner to a related
corporation are deductible under section 166 as a bad debt.
We hold they are not.
2. Whether petitioner is liable for the addition to tax
for delinquency determined by respondent under section
6651(a)(1). We hold it is.
3. Whether petitioner is liable for the accuracy-related
penalties 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
petitioner’s taxable year ended May 31, 1990, as the 1989 taxable
year. We refer to petitioner’s taxable year ended May 31, 1991,
as the 1990 taxable year. We refer to petitioner’s taxable year
ended May 31, 1992, as the 1991 taxable year.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and attached exhibits are incorporated
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