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$181,033, and a penalty pursuant to section 6663(a) of $689,198
with respect to petitioners' 1992 Federal income tax.1
The issues for decision are: (1) Whether petitioners are
entitled to defer recognition of gain on the disposition of
property located at 45640 North 23d Street West in Lancaster,
California (the 23d Street property), pursuant to section 1033;
(2) whether petitioners are liable for the fraud penalty pursuant
to section 6663(a), or, in the alternative, whether petitioners
are liable for the accuracy-related penalty pursuant to section
6662(a) for 1992; and (3) whether petitioners are liable for the
addition to tax for failure to timely file their return for 1992.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioners, husband and
wife, resided in Quartz Hills, California, at the time they filed
their petition.
The 23d Street Property
In 1982, the Lancaster Redevelopment Agency (the LRA)
prepared a Redevelopment Plan for the Lancaster Fox Field
Redevelopment Project pursuant to California Community
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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