- 2 - 6662(a) penalty of $2,661, for petitioners' 1991 taxable year. Respondent has conceded that petitioners are not liable for the section 6651(a)(1) addition to tax. After further concessions, the following issues remain for our consideration: (1) Whether petitioners are entitled to an ordinary or a capital loss deduction for funds expended in a business venture; (2) whether petitioners are liable for an accuracy-related penalty under section 6662 in the amount of $2,661. FINDINGS OF FACT2 Petitioners, Christopher A. Boyko and Roberta A. Boyko, are husband and wife and resided in Parma, Ohio, at the time their petition was filed in this case. Petitioners filed a joint return for the 1991 taxable year. Roberta Boyko is a party to this proceeding solely because she signed the joint return for 1991; consequently, Christopher Boyko is referred to herein as petitioner. Petitioner is a lawyer and has practiced law in Ohio since 1979. Until June 1987, petitioner practiced in the law practice of his father, Andrew Boyko. Petitioner practiced in a variety of areas, including personal injury, probate, and business law. In June 1987, petitioner acquired his father's law practice, and was subsequently elected to the office of Law Director for the 2The stipulation of facts and the attached exhibits are incorporated by this reference.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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