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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.
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