- 2 - William Whelpley, Jr., docket No. 21644-93: Addition to Tax Penalty Year Deficiency Sec. 6653 Sec. 6662 1987 $3,612 $181 -- 1989 1,148 -- $230 William and Sara Whelpley, docket No. 21690-93: Additions to Tax Penalty Year Deficiency Sec. 6653 Sec. 6661 Sec. 6662 1987 $26,076.87 $1,304 $6,519 -- 1989 22,047.87 -- -- $4,410 Unless stated otherwise, all section references are to the Internal Revenue Code as in effect during the years in issue. The above-captioned cases were consolidated for trial and briefing. After concessions by the parties, the issues remaining for decision are: (1) Whether certain payments made to petitioners' wholly owned S corporation are includable in petitioners' income and, if so, when the payments must be reported; (2) whether the notices of deficiency for petitioners' 1989 taxable year are valid; and, (3) whether petitioners are liable for the additions to tax and penalties determined by respondent under sections 6653(a)(1)(A), 6661, and 6662(a). FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts filed by the parties andPage: 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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