- 2 - Accuracy-Related Penalty Year Deficiency Sec. 6662(a) 1988 $ 1,351 --- 1989 19,046 $3,809 1990 16,430 3,286 1991 16,436 3,287 Pursuant to an amended answer, filed October 10, 1995, respondent seeks a $9,864 increase in the deficiency for 1988, so that the total amended amount of the proposed deficiency for that year is $11,215. Following concessions by petitioners, the issues for decision are: (1) The proper characterization (loans, as contended by petitioners, or wages, as contended by respondent) of monthly payments received by petitioner Mark D. Morgan from Robert Randall Co. We hold that such payments are wages, includable in petitioners' income. (2) Whether petitioners are entitled to claimed employee business expense deductions (for 1989, 1990, and 1991) for automobile expenses. Because of petitioners' failure to provide sufficient substantiation, we hold they are not. (3) Whether the increased deficiency asserted by respondent for 1988 is time-barred. We hold that it is not. (4) Whether petitioners are liable for the accuracy-related penalty under section 6662(a) for 1989, 1990, and 1991. We hold they are.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011