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All section references are to the 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. All dollar amounts are rounded to the nearest dollar,
unless otherwise indicated. After concessions,1 three issues
remain regarding petitioners' tax liability for 1990: (1) Whether
petitioners failed to report gain from the sale of property, (2)
whether petitioners are subject to an addition to tax under
section 6651(a)(1) for failure to timely file, and (3) whether
petitioners are subject to an accuracy-related penalty under
section 6662(a). We hold for respondent on all three issues.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulated facts and accompanying exhibits are incorporated
1 For 1990, respondent concedes that petitioners did not receive
income of $376,733, and that petitioners are not subject to a
self-employment tax of $7,849. Respondent further concedes that
petitioners incurred expenses of $12,395 attributable to the sale
of their Fort Lauderdale property, and that their basis in such
property is increased by $575.
For 1990, petitioners concede they are not entitled to deduct
compensation expense of $4,800, employment tax of $659, or one-
half of the self-employment tax of $3,134.
For 1991, respondent concedes that petitioners did not receive
income of $502,142, that petitioners are entitled to a deduction
for personal exemptions of $4,300, and that they are not subject
to a self-employment tax of $10,247. Respondent further concedes
that there is no deficiency in income tax due from petitioners
for 1991, and that petitioners are not subject to the addition to
tax under sec. 6651(a)(1), nor a penalty under sec. 6662(a) for
that year.
For 1991, petitioners concede they are not entitled to deduct
compensation expense of $9,200, employment tax of $1,298, or one-
half of the self-employment tax of $3,968, and that no
overpayment is due them for that year.
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