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8. Whether Eicher may include in gross income $73,122 of
interest related to loans he made to Hersco. We hold that he may
not.
9. Whether Wise and Eicher had enough basis in WRI on July
31, 1988, to deduct their shares of WRI's net operating loss. We
hold that they did not.
10. Whether the Wises are liable for the addition to tax
for negligence under section 6653(a). We hold that they are.
11. Whether the Wises are liable for the addition to tax
for substantial understatement of tax under section 6661. We
hold that they are if they substantially underpaid tax for 1988.
12. Whether Eicher is liable for the addition to tax for
substantial understatement of tax under section 6661. We hold
that he is if he substantially underpaid tax for 1988.
Section references are to the Internal Revenue Code in
effect for the year in issue. Rule references are to the Tax
Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioners
The Wises lived in Florida and Eicher lived in Brazil when
they filed the petitions in these cases. Eicher is a U.S.
citizen, but has lived in Brazil since the early 1950's. He
worked for the Unisys Corporation until 1992. Eicher used the
address, "c/o 938 Wald Road, Orlando, Florida", on his petition.
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