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section 6662(a) in the respective amounts of $2,700, $5,181, and
$4,267 for 1989, 1990, and 1991. All section references are to
the Internal Revenue Code in effect for the years in issue. All
Rule references are to the Tax Court Rules of Practice and
Procedure. After concessions,1 the issues for decision are:
(1) Whether petitioners overstated the Yogurt Station,
Inc.'s, (Yogurt Station)2 automobile mileage deductions for 1989,
1990, and 1991;
(2) whether petitioners understated the Yogurt Station's
gross income for 1989, 1990, and 1991, as determined by
respondent;
(3) whether petitioners understated the Yogurt Station's
deductions for 1989, 1990, and 1991;
(4) whether petitioners are liable for accuracy-related
penalties under section 6662(a) with respect to the underpayments
of tax resulting from their failure to report dividend income of
$26, $992, and $1,726 for the years 1989, 1990, and 1991,
respectively; and
(5) whether petitioners are liable for penalties for fraud
pursuant to section 6663 for 1989, 1990, and 1991; or in the
1 Petitioners have conceded that they received, but did not
report on their individual Federal income tax returns, taxable
dividend income in the amounts of $26, $992, and $1,726 for the
years 1989, 1990, and 1991, respectively.
2 The Yogurt Station's business activity was reported on Form
1120S, U.S. Income Tax Return for an S Corporation. The record
does not establish whether the Yogurt Station was a validly
formed corporation. However, since the Yogurt Station was wholly
owned by petitioner Richard McGirl, this void in the record does
not affect our decision.
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