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Additions and Penalty
Sec. Sec. Sec.
Petitioner Deficiency 6651(a) 6655 6662(b)(1)
Group $23,201 $5,800.25 $1,543 ---
Administration
Premium Services,
Inc.
Jerome J. and 39,446 9,668.00 --- $7,998.29
Joanne L. Mancuso
Jerome J. Mancuso 5,845 1,461.25 389 ---
& Associates,
Inc.
The cases were consolidated for trial, briefing, and
opinion. All references to petitioner are to Jerome J. Mancuso.
All section references are to the Internal Revenue Code in effect
for the year in issue, and all Rule references are to the Tax
Court Rules of Practice and Procedure.
After concessions by the parties, the issues remaining for
decision are: (1) Whether petitioner corporations Group
Administration Premium Services, Inc. (GAPS), and Jerome J.
Mancuso & Associates, Inc. (JJM), are entitled to expense
deductions in excess of the amounts allowed in the notices of
deficiency and conceded by respondent; (2) whether GAPS's and
JJM's payments to petitioner, and on his behalf, were repayments
of shareholder loans or corporate distributions; and (3) whether
the respective petitioners are liable for the following: (a) all
petitioners for the addition to tax under section 6651(a)(1) for
failure to file timely income tax returns; (b) petitioners
Jerome J. and Joanne L. Mancuso for the accuracy-related penalty
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Last modified: May 25, 2011