- 2 - Accuracy-Related Penalties - Sec. 6662(a)2 Year Deficiency Sec. 6662(b)(1) Sec. 6662(b)(2) 1990 $14,753 --- $2,815 1991 4,195 $839 --- 1992 3,956 791 --- Several issues have been conceded or settled by the parties. The issues presented for decision are: (1) Whether petitioners are entitled to claimed losses incurred in their model railroad activity for 1990, 1991, and 1992, so as to allow the expenses in excess of the income from the activity to be deducted for Federal income tax purposes; (2) whether petitioners are entitled to a nonbusiness bad debt deduction for 1990; (3) whether amounts received by petitioner James J. Lencke as residual insurance premiums and in lieu of renewal insurance commissions during 1990 and 1991 are subject to self-employment tax under sections 1401 and 1402; (4) whether petitioners are liable for an accuracy- related penalty for an underpayment of tax attributable to a substantial understatement for 1990; and (5) whether petitioners are liable for accuracy-related penalties for negligence or disregard of rules or regulations for 1991 and 1992. FINDINGS OF FACT Some of the facts have been stipulated and are found accordingly. The stipulation of facts and three supplemental 2 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, unless otherwise indicated.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011