MEMORANDUM FINDINGS OF FACT AND OPINION NIMS, Judge: Respondent determined the following income tax deficiencies, additions to tax, and penalty with respect to petitioners' 1988 and 1989 taxable years: Additions to Tax Penalty Taxable Sec. Sec. Sec. Sec. Year Deficiency 6651(a)(1) 6653(a)(1) 6661 6662(a) 1988 $28,495 $2,479 $1,425 $7,124 -0- 1989 4,550 -0- -0- -0- $910 Unless otherwise indicated, all section references are to sections of the Internal Revenue Code in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. After concessions, the issues for decision are: 1. Did petitioners have unreported income of $61,353 and $4,666 for 1988 and 1989, respectively? 2. Did petitioners have unreported interest income of $84 and $214 for 1988 and 1989, respectively? 3. Did petitioners have a loss of $350,000 on the disposition of real estate in 1988?Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011