- 2 - 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 didPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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