- 2 - Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated. In docket No. 5220-95, respondent issued a notice of final S corporation administrative adjustment (FSAA) to Douglas J. Von Allmen, tax matters person of State Supply Warehouse Co. (State Supply), setting forth the following adjustments with respect to State Supply's 1989 taxable year: Item FSAA Adjustment Amount in Dispute Sales promotion $7,065 -0- Covenant not to compete 673,560 $673,560 During the 1990 tax year, State Supply was an S corporation not subject to the unified audit and litigation procedures of the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, sec. 402(a), 96 Stat. 324, 648. All of respondent's adjustments to State Supply flowed directly through to its shareholders' tax returns. Respondent determined the following deficiencies in, and penalty on, petitioners' Federal income tax: Charles B. and Teresa A. Thompson--docket No. 5219-95 Year Deficiency 1990 $8,638 Douglas J. and Linda L. Von Allmen--docket No. 16787-95 Accuracy-related Penalty Year Deficiency Sec. 6662(a) 1990 $88,319 $17,664Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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