- 2 - Accuracy-Related Addition to Tax Penalty Year Deficiency Sec. 6651(a) Sec. 6662(a) 1988 $ 502 -- -- 1989 4,148 $1,058 -- 1990 9,335 -- $1,871 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. All references to petitioner are to Kent Jensen. The issue for decision is whether petitioners are entitled either to a section 166 business bad debt deduction with respect to $128,841 that was transferred to petitioners’ closely held corporation or to a section 1244 ordinary loss deduction in the same amount with respect to the stock of petitioners’ closely held corporation. FINDINGS OF FACT Some of the facts have been stipulated and are so found. When the petition was filed, petitioners resided in Centerville, Utah. On July 23, 1984, petitioners organized K&C Industries (K&C) as a corporation to market and sell artificial fingernails. Petitioner served as president and treasurer of K&C, and Carol Jensen served as vice president and secretary of K&C. At the time of K&C's formation, petitioners contributed to K&C $5,882 in cash, office furniture, and a computer system.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011