- 2 - Gary L. Pierce and Mary C. Pierce Penalty Year Deficiency Sec. 6662(a)1 1984 $3,513 $703 1986 71,974 14,395 1987 539,914 1105,833 1988 527,851 105,570 1989 102,323 20,465 1 For taxable year 1987, the penalty pursuant to sec. 6662(a) is shown in the statutory notice as both $151,729 and $105,833. The correct amount is $105,833. Gary L. Pierce Penalty Year Deficiency Sec. 6662(a) 1991 $444,040 $88,808 By reason of respondent’s concessions, the remaining issues for decision are: (1) Whether Mary Catherine Development Co. (Mary Catherine), an S corporation engaged in buying and developing land for sale to residential builders, was entitled to use the lower of cost or market (LCM) method, an inventory method of accounting, for taxable years 1989 and 1990 to claim reductions of income for decreases in the fair market value of parcels of land held for development; and (2) whether Gary L. Pierce (petitioner) and Mary C. Pierce are liable for accuracy- related penalties for the years 1984, 1986 through 1989, and 1991 pursuant to section 6662(a) for negligence or intentional 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure. Dollar amounts have been rounded to the nearest dollar.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