- 2 - Respondent determined a deficiency of $8,116 in Federal income tax and an accuracy-related penalty under section 6662(a) in the amount of $1,623 for petitioners' 1992 tax year. After a concession by petitioners, the issues for decision are whether petitioners properly substantiated certain trade or business expenses under section 274(d), and whether petitioners are liable for the penalty under section 6662(a) for a substantial understatement of tax under section 6662(b)(2).2 Some of the facts were stipulated. Those facts, with the annexed exhibits, are so found and are incorporated herein by reference. At the time the petition was filed, petitioners were legal residents of Tulsa, Oklahoma. During the year in question, Michael E. Hentges (petitioner) was primarily engaged in the sale of insurance and securities and, to some extent, engaged in estate planning and financial consultation. He has been in such business since 1984. Many of his clients were located in various States. Petitioner made frequent business trips to contact and solicit new clients, and virtually all of his travel was by private plane, which he rented. For local transportation, petitioner owned a 1983 Mercedes automobile that he used exclusively in his business. 2 At trial, petitioners conceded an adjustment in the notice of deficiency for their failure to report as income on their 1992 return an IRA distribution of $6,220. Petitioners also conceded the 10-percent additional tax under sec. 72(t) for the early distribution of the IRA.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011