- 2 - Held, further: P failed to substantiate a part of his basis in Company Y. Held, further: R's calculation of the interest portion on the loan from Bank X is sustained. Held, further: P failed to substantiate $19,975 of attorney's fees. Held, further: P is not liable for the accuracy- related penalty under sec. 6662(a). David M. Berrett, for petitioners. William R. Davis, Jr., for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION FAY, Judge: Respondent determined deficiencies in peti- tioners' Federal income taxes and penalties as follows: Penalty Year Deficiency Sec. 66631 1990 $815,589 $611,692 1991 1,069 802 1 Prior to trial, respondent conceded that no amounts were due to fraud. In her answer to the petition, respondent asserted an accuracy- related penalty against petitioners pursuant to sec. 6662(a). All section references are to the Internal Revenue Code in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated. A trial was held to resolve the following issues for decision:Page: 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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