- 7 - (6) Whether the Takaos are liable for an addition to tax for substantial underpayment of tax under section 6661 for 1988. We hold that they are. Toraya Corporation(docket No. 19181-94) After concessions,4 the following issues remain in dispute: (1) 4 In a stipulation of settled issues filed Dec. 4, 1995, and an amended stipulation of settled issues filed May 14, 1996, the parties agreed as follows: 1. Respondent concedes that adjustments for "Purchase Expense" should be decreased as follows: 1988 $30,733 1989 5,114 1990 25,230 1991 24,000 Respondent also concedes that Toraya is entitled to an additional $6,000 purchase expense in 1990. 2. Respondent concedes adjustments for "Amortization Expense" for all years in issue. 3. Respondent and Toraya agree that adjustments for "Business Travel" are settled by reducing the amounts shown as follows: 1988 $8,931 1990 4,400 1991 3,606 4. Respondent and Toraya agree that adjustments for "Truck Expense" for all years in issue are settled by reducing the amounts as follows: 1988 $13,000 1989 4,123 1990 3,936 1991 2,009 5. Toraya concedes that the adjustment for "Employee Meeting Expense" for 1988 in the amount of $6,455 is correct. 6. Respondent concedes that the adjustment for "Office Expenses" for 1988 should be reduced by $1,800. The remaining amounts for the years in issue under this adjustment remain in dispute. 7. Respondent concedes adjustments entitled "Restaurant Expenses" for 1988 and 1989. 8. Respondent concedes the adjustment for "Rent Expenses" for 1988. 9. Respondent concedes adjustments entitled "Depreciation Expenses -- Auto" and "Depreciation Expenses -- Other" for all (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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