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amount of $769 and an accuracy-related penalty pursuant to
section 6662(a) in the amount of $2,162.
After concessions by respondent, the issues remaining for
decision are: (1) Whether the period of limitations for the
assessment of a deficiency had expired at the time of the
issuance of the notice of deficiency; (2) whether petitioners had
unreported Schedule C income in the amount of $15,000; (3)
whether petitioners are entitled to exclude from income $300 that
they received from the Herkeios Group as reimbursement for
educational expenses; (4) whether petitioners are entitled to
exclude $1,688.92 that they received from the Herkeios Group as
reimbursement for health care expenses; and (5) whether
petitioners are liable for an accuracy-related penalty pursuant
to section 6662(a).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
Petitioners resided in San Diego, California, when they filed
their petition in this case. For all relevant periods,
petitioners were cash basis taxpayers.
On February 12, 1991, petitioners transferred J.S. Khalsa
Co., their high-rise window-washing business, into a trust called
1(...continued)
Practice and Procedure.
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