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Penalty
Year Deficiency Sec. 6662
1989 $6,313 $1,263
1990 17,439 3,488
After concessions by both parties, the issues for decision
are: (1) Whether petitioner failed to report income for 1989 and
1990 in the amounts of $7,439 and $36,663, respectively; and (2)
whether petitioner is liable for negligence penalties under
section 6662(a). We hold for respondent on both issues.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations of fact and attached exhibits are incorporated
by this reference. At the time the petition was filed,
petitioner’s legal residence was in Reevesville, South Carolina.
During the years at issue petitioner operated a farm. The
primary sources of petitioner’s income were sales of cattle,
soybeans and grain. Petitioner maintained a single bank account
at the First Federal Savings & Loan of Walterboro for both
personal and business use. He did not deposit all farm receipts
into this bank account. He endorsed to third-party creditors
some of the checks he received. Petitioner concedes that he
failed to maintain adequate books and records to account for his
farming activities during the years at issue. He further
concedes that his Federal income tax returns for these years did
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