Emmett I. and Shirley Sindik - Page 2

                                        - 2 -                                         
                                   Additions to Tax and Penalties                     
                                   Sec.           Sec.      Sec.                      
          Year      Deficiency     6653(a)(1)     6661(a)   6662(a)                   
          1988      $9,864         $493           $2,020    -0-                       
          1989      13,603         -0-            -0-       $2,603                    
          1990      29,476         -0-            -0-       5,895                     
               After concessions by the parties, which will be given effect           
          in the Rule 1551 computation, the issues for decision are:                  
               (1) Whether petitioners understated gross receipts for                 
          taxable years 1988, 1989, and 1990 in the amounts of $27,678,               
          $27,016, and $39,219, respectively, as determined by respondent.            
          We hold that they did.                                                      
               (2) Whether petitioners overstated business expense                    
          deductions for the taxable years at issue as determined by                  
          respondent.  We hold that they did.                                         
               (3) Whether petitioners had unreported capital gain for                
          taxable year 1990 in the amount of $38,700 as determined by                 
          respondent.  We hold that they did.                                         
               (4)  Whether petitioners are liable for an addition to tax             
          for negligence under section 6653(a)(1) for taxable year 1988 and           
          accuracy-related penalties for negligence under section 6662(a)             
          for taxable years 1989 and 1990.  We hold that they are.                    




               1Unless otherwise indicated, all section references are to             
          the Internal Revenue Code in effect for the years at issue, and             
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  




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