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a result of payments made by Home Shopping Network, Inc., to
Pioneer Data Processing, Inc., pursuant to a license agreement;
(2) if so, whether amounts equal to these license payments
constituted taxable gifts to petitioners' son, Richard M. Speer,
who owned all the stock of Pioneer Data Processing, Inc.; (3)
whether petitioners’ claimed losses from two subchapter S
corporations during the taxable years 1988 through 1990 are
passive activity losses as defined in section 469;2 (4) whether
petitioners are liable for the addition to tax for negligence
under section 6653(a)(1) for the taxable year 1988; (5) whether
petitioners are liable for the accuracy-related penalty under
section 6662 for the taxable years 1989 and 1990; (6) whether
petitioners are liable for the addition to tax for a substantial
understatement of tax liability under section 6661(a) for the
taxable year 1988; and (7) whether petitioner Roy M. Speer is
liable for additions to tax under section 6651(a)(1) for failure
to file a timely gift tax return for the taxable years 1985
through 1989.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the first, second, third, and fourth
2Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the taxable years in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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