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Respondent determined a deficiency in petitioners' 1991
Federal income tax in the amount of $1,283.
After concessions2, the issues for decision are: (1)
Whether petitioners underreported their income for 1991; and
(2) whether respondent's oral motion for a penalty under section
6673 should be granted.
Some of the facts have been stipulated and are so found.
The stipulations of fact and attached exhibits are incorporated
herein by this reference. Petitioners resided in Federal Way,
Washington, on the date the petition was filed in this case.
Hereinafter, references to petitioner in the singular are to
Michael Rough.
In 1991, petitioner sold Amway products for which he was
compensated in the form of a sales commission. In 1991, in
connection with his sales commissions from his Amway business,
petitioner received a Form 1099 from Don and Roberta Langeliers
in the amount of $1,957.54 (Langeliers Form 1099) and a Form 1099
from Sean and Jade Mullaney in the amount of $2,614.61 (Mullaney
Form 1099).
On their 1991 Federal income tax return, petitioners failed
to report petitioner's sales commission income or any related
expenses in connection with petitioner's Amway sales business.
2 Petitioner Michael Rough conceded that he received
commissions from his Amway sales business as determined by
respondent with the exception of two checks totaling $94.62.
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