- 2 - Penalty Year Deficiency Sec. 6662 1990 $470 $270 1991 4,345 1,114 1992 5,320 1,428 All section references are to the Internal Revenue Code, as in effect during the years in issue. We are called upon to decide three questions: First, whether petitioners can deduct the value of certain uncompensated medical services that Dr. Remy provided to his patients, as an advertising expense under section 162; second, whether the subject tax deficiencies should be disallowed on the ground that the original revenue agent's report contained "gross errors of fact"; third, whether petitioners are liable for the accuracy-related penalty under section 6662(a). FINDINGS OF FACT Some of the facts have been stipulated by the parties. The stipulation of facts, the supplemental stipulation of facts, and the exhibits attached thereto are hereby incorporated in this opinion. At the time the subject petition was filed in this Court, petitioners resided in the State of Oklahoma. In this opinion, references to petitioner are references to Dr. Bruce K. Remy.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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