- 2 - Accuracy-Related Addition to Tax Penalty Year Deficiency Sec. 6651(a)(1) Sec. 6662(a) 1991 $15,983 $2,693 $3,196 1992 8,798 -- 1,760 Unless otherwise indicated, 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. After settlement, the issues for decision in these consolidated cases are: (1) Whether petitioner may exclude from gross income a $37,767 bonus received from his employer; (2) whether petitioner may deduct $5,433 as an investment interest expense; (3) whether petitioner has substantiated $31,796 in claimed business expenses; (4) whether, for 1992, petitioner is entitled to "single" filing status; (5) whether petitioner is subject to the alternative minimum tax; and (6) whether petitioner is liable for the addition to tax and the accuracy- related penalties. FINDINGS OF FACT Many of the facts have been stipulated and are so found. At the time the petition was filed, petitioner resided in Verona, New Jersey. In 1988, petitioner was employed as a stockbroker by Dean Witter Reynolds, Inc. (Dean Witter). As an inducement for andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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