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Accuracy-Related Penalty
Year Deficiency Sec. 6662(a)
1990 $7,849 $1,570
1991 9,613 1,923
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. References to petitioner are to William T. Hough.
The only issue for decision is whether for purposes of
calculating petitioners' self-employment tax liabilities for 1990
and 1991 certain deposits and claimed partnership losses may be
deducted on Schedule C of petitioners' joint Federal income tax
returns.
FINDINGS OF FACT
Many of the facts have been stipulated and are so found. At
the time the petition was filed, petitioners resided in Basking
Ridge, New Jersey.
During the 1970's and part of the 1980's, petitioner
practiced law through his professional law corporation (PC), and
petitioner established through his PC a money purchase pension
plan.
In 1975, petitioner received a favorable determination
letter from respondent regarding the money purchase pension plan.
Respondent's determination letter qualified the plan so that for
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