Kenneth D. Shepherd and Martha A. Gregory - Page 2

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               Respondent determined deficiencies in petitioners' Federal             
          income taxes, an addition to tax, and penalties as follows:                 
                              Addition to Tax           Penalties                     
          Year   Deficiency   Sec. 6651(a)(1)   Sec. 6662(a)   Sec. 6663(a)           
          1991     $2,586          ---            $258           $974                 
          1992      2,002          $79            133            1,001                
               After concessions,2 the issues for decision are:  (1)                  
          Whether petitioners are entitled to claim trade or business                 
          deductions; (2) whether petitioners are entitled to claim a bad             
          debt deduction; (3) whether petitioners are liable for the                  
          section 6651(a)(1) addition to tax for 1992; (4) whether                    
          petitioners are liable for the section 6663(a) penalty for fraud;           
          and (5) whether petitioners are liable for the section 6662(a)              
          accuracy-related penalty for negligence.                                    
               Some of the facts have been stipulated and are so found.               
          The stipulations of fact and attached exhibits are incorporated             
          herein by this reference.  Petitioners resided in Tulsa,                    
          Oklahoma, on the date the petition was filed in this case.                  
               Petitioner wife worked full time as a librarian at the Tulsa           
          City County library.  After her regular work hours, petitioner              
          wife performed limited research services for her brother and at             



          2         In their petition, petitioners failed to address                  
          respondent's determinations that they received and failed to                
          report: (1) Capital gain on the sale of a mutual fund in taxable            
          year 1991; (2) interest income in taxable year 1992; and (3) a              
          state income tax refund in taxable year 1992.  We deem                      
          petitioners to have conceded these items.  Rule 34(b)(4).                   




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