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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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