- 2 -
1990 $8,085 --
1991 12,289 $863
1992 10,239 --
Respondent has conceded that petitioners are not liable for
the section 6651(a)(1) addition to tax. In an amendment to her
answer, respondent asserted for the first time that petitioners,
pursuant to section 6662(a), are liable for negligence penalties
of $1,617, $2,458, and $2,048 for years 1990, 1991, and 1992,
respectively.
Unless otherwise indicated, all section references are to
the Internal Revenue Code for the years in issue, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
The issues for decision are as follows:
1. Whether petitioners are entitled to claimed bad debt
deductions. We hold they are not.
2. Whether petitioners are entitled to claimed deductions
for unreimbursed partnership expenses. We hold they are not.
3. Whether petitioners, pursuant to section 6662(a), are
liable for an accuracy-related penalty for negligence. We hold
they are.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. At
the time the petition was filed, petitioners resided in Santa
Claus, Indiana.
David E. Price (petitioner) has been an attorney since 1970.
Between 1970 and 1977, he served as an attorney for the Internal
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