Debra L. Streck and Donald W. Streck - Page 3

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          Petitioners concede the adjustments made by respondent for                  
          unreported gross income, the allowance of the two-earner                    
          deduction, and the increase to capital gains.  Petitioners also             
          concede that Mr. Streck is liable for the additions to tax under            
          section 6653(b)(1)6 and (2) for the taxable years 1983, 1984, and           
          1985, and agree with respondent that the addition to tax under              
          section 6653(b)(2) is applicable only to the tax attributable to            
          unreported income.  Respondent concedes that Mrs. Streck is not             
          liable for the additions to tax under section 6653(b)(1) and (2)            
          for any of the years at issue.                                              
               The issues remaining for decision are:  (1) Whether                    
          respondent is bound by an alleged settlement agreement for the              
          years at issue; (2) whether petitioners are entitled to                     
          deductions for losses they claimed were sustained by Double D               
          Ranch, Inc., an S corporation; (3)whether Mrs. Streck is entitled           
          to innocent spouse relief pursuant to section 6013(e); (4)                  
          whether petitioners are liable for the addition to tax pursuant             

               5(...continued)                                                        
          the following items:  Business expenses in the amount of $42,500            
          for 1984; legal and professional fees in the amount of $16,014              
          for 1984; losses related to petitioners' ownership of Double D              
          Ranch, Inc., an S corporation, in the amounts of $200,331,                  
          $255,302, and $229,232 for 1984, 1985, and 1986, respectively;              
          and real estate taxes in the amount of $22,994 for 1985.                    
          Respondent allowed an increase in expenses related to legal and             
          professional fees in the amount of $2,848 in 1985.                          
               6Unless otherwise indicated, all section references are to             
          the Internal Revenue Code in effect for the taxable years in                
          issue, and all Rule references are to the Tax Court Rules of                
          Practice and Procedure.                                                     




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