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Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
The issues to be decided in these cases are as follows:
(1) Whether the statute of limitations precludes assessment
and collection for any of the taxable years 1985 through 1989;
(2) whether Dennis C. Gandy and Carolyn S. Gandy
(petitioners) received unreported Schedule F income from Dennis
Gandy Nursery (the nursery) for 1985 through 1987;
(3) whether Dennis C. Gandy (Mr. Gandy) received unreported
Schedule F income from the nursery for 1988 and 1989;
(4) whether petitioners received unreported interest income
for 1985 and 1986 and overreported such income for 1987;
(5) whether petitioners failed to report capital gain income
for 1987;
(6) whether petitioners are entitled to a net operating loss
deduction for 1985;
(7) whether petitioners are liable for the additions to tax
for fraud or for negligence for 1985 through 1987;
(8) whether Mr. Gandy is liable for the addition to tax for
fraud or for negligence for 1988 and for the fraud or negligence
penalty for 1989;
(9) whether petitioners are liable for an addition to tax
for delinquency for 1987;
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Last modified: May 25, 2011