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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 incorporated
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