- 2 - MEMORANDUM FINDINGS OF FACT AND OPINION HALPERN, Judge: For petitioners’ taxable (calender) year 1990, respondent determined a deficiency in petitioners’ Federal income tax liability of $28,694 and an accuracy-related penalty of $371. The issues remaining for decision are: (1) Whether, during 1990, petitioner husband was a shareholder in an S corporation so that petitioners are required to report his pro rata share of the corporation’s income and certain other items, (2) whether petitioners failed to report $6,500 of nonemployee compensation received by petitioner husband from the S corporation in 1990, and (3) whether petitioners were negligent in filing their 1990 return. Unless otherwise noted, all section references are to the Internal Revenue Code in effect for the taxable year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. FINDINGS OF FACT Introduction Petitioners are husband and wife, who, for 1990, made a joint return of Federal income tax liability. Petitioners resided in Los Altos Hills, California, at the time the petition in this case was filed. Petitioner husband (hereafter, petitioner) is an attorney and member of the California bar.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011