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Addition to Tax Accuracy-Related Penalty
Section Section
Year Deficiency 6651(a)(1)1 6662(a)
1992 $14,735 $1,335 $2,947
The issues for decision are:
(1) Do petitioners have unreported income for 1992? We hold
that they do to the extent stated herein.
(2) Are petitioners liable for self-employment tax under
section 1401(a)? We hold that they are to the extent stated
herein.
(3) Are petitioners liable for the addition to tax under
section 6651(a)(1)? We hold that they are to the extent stated
herein.
(4) Are petitioners liable for the accuracy-related penalty
under section 6662(a)? We hold that they are to the extent
stated herein.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioners resided in Hollis, New York, at the time the
petition was filed.
Although petitioners did not request an extension of time
within which to file their Federal income tax return for 1992,
they filed a joint U.S. individual income tax return for that
year (1992 return) on May 24, 1993. Petitioners reported $8,938
1 All section references are to the Internal Revenue Code in
effect for the year at issue. All Rule references are to the Tax
Court Rules of Practice and Procedure.
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