- 2 - James H. and Stacy Leste Docket No. 17310-94 Accuracy-Related Penalty Year Deficiency Sec. 6662(a) 1991 $14,467 $2,893 Richard W. and Katherine J. Moore Docket No. 17311-94 Accuracy-Related Penalty Year Deficiency Sec. 6662(a) 1989 $37,712 $7,542 1990 15,708 7,469 1991 18,930 3,786 James H. Leste Docket No. 17312-94 Accuracy-Related Penalty Year Deficiency Sec. 6662(a) 1989 $40,312 $8,062 1990 21,954 4,391 First Associates Mortgage Corp. Docket No. 17420-94 Year Addition to Tax Accuracy-Related Penalty Ended Deficiency Sec. 6651(a)(1) Sec. 6662(a) 10/31/89 $82,867 -- $16,573 10/31/90 52,626 -- 10,525 10/31/91 92,046 $12,625 18,409 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. After concessions, the issues for decision are: (1) Whether payments made by corporate petitioner First Associates Mortgage Corp. (FAMC) to Valentine Silbernagel (Silbernagel), pursuant to a consulting and noncompetition agreement, represent compensation deductible under section 162(a), as petitioners contend, or additional consideration to ValentinePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011