- 2 - Respondent determined deficiencies in petitioners' Federal income taxes and accuracy-related penalties for the years as follows: Petitioners J. Michael Joly and Bonnie B. Joly Accuracy-Related Year Deficiency Penalty 1992 $5,478 $1,096 1993 3,464 693 1994 1,951 390 Petitioner Jody Steven Joly Year Deficiency 1993 $1,020 1994 1,583 Petitioner David Andrew Joly Year Deficiency 1992 $2,143 After concessions, the issues remaining for decision are: (1) Whether certain amounts paid to or on behalf of J. Michael Joly and Jody Steven Joly by J. Michael Joly, Inc. constitute employee wages; (2) the correct method of computing the amounts of the losses and gains that J. Michael Joly, Jody Steven Joly, and David Andrew Joly must recognize with respect to their J. Michael Joly, Inc. stock; and (3) whether J. Michael Joly and Bonnie B. Joly are liable for the section 6662(a) accuracy- related penalties. Some of the facts have been stipulated and are so found. The stipulations of fact and attached exhibits are incorporatedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011