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Addition to Tax and Penalties
Year Deficiency Sec. 6651 Sec. 6662(a)
1991 $4,566 -0- $913
1992 11,268 $330 2,254
Unless 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.
The issues for decision are:
(1) Whether petitioners are entitled to deduct a net
operating loss (NOL) consisting of estimated potential wages lost
when George Kukes (petitioner) was terminated by his employer in
1984. We hold they are not.
(2) Whether petitioner was in a trade or business concerning
his music activities in 1992. We hold he was not.
(3) Whether petitioners are subject to an addition to tax
for delinquent filing of their 1992 income tax return. We hold
that they are.
(4) Whether petitioners are subject to a negligence penalty
for 1991 and 1992. We hold they are.
Petitioners have conceded the remaining issues raised in the
notice of deficiency.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
When they filed their petition in this case, petitioners resided
in Roseville, California.
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Last modified: May 25, 2011