David E. and Mary R. Price - Page 2

                                        - 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            




Page:  Previous  1  2  3  4  5  6  7  8  Next

Last modified: May 25, 2011