- 2 -2 substantial understatement of tax pursuant to section 6662. The deficiency primarily relates to Sam E. Scott's (petitioner) withdrawal from his law firm partnership. After concessions, the following issues remain for decision: (1) Whether petitioner was entitled to a $121,500 loss deduction due to his withdrawal from his law firm partnership; (2) whether petitioner received an $85,455 taxable distribution from his law firm's 401(k) plan; (3) whether petitioner is entitled to a $33,943 interest expense deduction; (4) whether petitioner is liable for an addition to tax for failure to timely file his 1991 Federal income tax return pursuant to section 6651(a)(1); and (5) whether petitioner is liable for an accuracy-related penalty for the substantial understatement of tax pursuant to section 6662. All section references are to the Internal Revenue Code as in effect for the year in issue, unless otherwise indicated. All Rule references are to the Tax Court Rules of Practice and Procedure. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. Petitioner resided in Hazlehurst, Mississippi, at the time he filed his petition.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