Robert W. and Jennifer J. Fritz - Page 2

                                        - 2 -                                         
                         Additions to Tax                                             
          Year  Deficiency  Sec. 6653(a)(1)(A)  Sec. 6653(a)(1)(B)  Sec. 6661         
          1987    $5,503          $275          50 percent of the     $1,376          
          interest due on                                                             
          $5,503                                                                      

               The issues for decision are:  (1) Whether petitioners are              
          entitled to a deduction of $9,643 in 1987 for car and truck                 
          expenses; (2) whether petitioners have proven that they are                 
          entitled to a basis in their shares of La-Z-Boy stock sold during           
          1985 that is in excess of the basis determined by respondent; (3)           
          whether petitioners are liable for an addition to tax under                 
          section 6651(a)(1)1 for delinquent filing of their 1985 Federal             
          income tax return; (4) whether petitioners are liable for an                
          addition to tax under section 6653(a) for negligence or                     
          intentional disregard of rules or regulations for the taxable               
          years 1985 and 1987; and (5) whether petitioners are liable for             
          an addition to tax for a substantial understatement of income tax           
          under section 6661(a) for the taxable years 1985 and 1987.                  

                                     Background                                       

               Petitioners resided in Washington, Pennsylvania, at the time           
          the petition was filed.                                                     

          Fritz Tree Service                                                          

          1Unless otherwise indicated, all section references are to                  
          the Internal Revenue Code in effect for the taxable years in                
          issue, and all Rule references are to the Tax Court Rules of                
          Practice and Procedure.                                                     




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