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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 and
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