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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 Valentine
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Last modified: May 25, 2011