Sam E. Scott - Page 2

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          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.                                                         








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