M.S. Food Stores, Inc. - Page 4

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          to tax under section 6651(a)(1) for its taxable years ending                
          September 30, 1987, and 1988;                                               
               (4) whether the corporate petitioner is liable for additions           
          to tax for negligence for its taxable year ending September 30,             
          1986, under section 6653(a)(1) and (2); for its taxable years               
          ending September 30, 1987, and 1988, under section 6653(a)(1)(A)            
          and (B); and for its taxable year ending September 30, 1989,                
          under section 6653(a)(1); and for an accuracy-related penalty for           
          negligence for its taxable year ending September 30, 1990, under            
          section 6662(a);                                                            
               (5) whether the corporate petitioner is liable for an                  
          addition to tax under section 6661 for its taxable year ending              
          September 30, 1988;                                                         
               (6) whether petitioners Frederick Malcolm Sutton and Carolyn           
          P. Sutton (the Suttons) had unreported income, in the taxable               
          years 1986, 1987, 1988, and 1990, from rebate and coupon checks             
          diverted from the corporate petitioner;                                     
               (7) whether the Suttons had additional unreported income, in           
          the taxable years 1986 through 1990, from diverted corporate                
          funds (unexplained bank deposits);                                          
               (8) whether the Suttons are liable for additions to tax                
          under section 6651(a)(1) for the taxable years 1987 through 1990;           
               (9) whether the Suttons are liable for additions to tax for            
          negligence for the taxable years 1986 and 1987 under section                
          6653(a)(1)(A) and (B); and for the taxable year 1988 under                  




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