- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011