Southern Boiler Sales & Service, Inc. - Page 9

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          not explain the basis of the allocation between the 2 years.                
          Petitioner stipulated to those additional amounts of interest               
          income.                                                                     
               Of the other deductions of $94,105 No. 2 deducted for its              
          taxable year ended April 30, 1990, and $29,303 for its taxable              
          year ended April 30, 1991, the deficiency notice increased                  
          petitioner's other deductions by $57,585 for a total of $124,854            
          for its taxable year ended July 31, 1989, and by $126,540 for a             
          total of $207,092 for its taxable year ended July 31, 1990.                 
          These total increased other deductions of $184,125 exceed No. 2's           
          claimed total other deductions by an amount of $60,717.  The                
          record does not explain the source of these additional                      
          deductions, but neither party has challenged this adjustment.               
               Petitioner deducted depreciation of $16,851 for its taxable            
          year ended July 31, 1989, and $18,399 for its taxable year ended            
          July 31, 1990.  No. 2 claimed no depreciation deductions.                   
          Respondent disallowed $6,513 of petitioner's claimed depreciation           
          each year, the portion relating to a Chrysler New Yorker                    
          automobile and a boat.  Petitioner has conceded that adjustment.            
               Respondent determined an addition to tax for negligence                
          under section 6653(a) for the taxable year ended July 31, 1989,             
          and a penalty for negligence under section 6662(a) for the                  
          taxable year ended July 31, 1990.  Respondent determined the                
          addition and penalty on the full amounts of the deficiencies,               
          taking into account the tax shown on the tax returns filed by               




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