- 9 - (3) Whether Toraya is entitled to claim or treat as cost of goods sold the payments made to Joan Takao (Joan) and Junichi Takao (Junichi) in the amounts of $27,000 to Joan in 1988, and $7,100 to Joan and $4,000 to Junichi in 1989. We hold that it is entitled to claim them to the extent decided herein. (4) Whether Toraya is entitled to claim as cost of goods sold $19,917 in 1989, representing the beginning inventory balance of a restaurant Toraya closed that year. We hold that it is to the extent decided herein. (5) Whether Toraya is liable for an addition to tax for late filing under section 6651(a) for 1988.6 We hold that it is. (6) Whether Toraya is liable for an addition to tax for negligence under section 6653(a)(1) for 1988, and accuracy- related penalties under section 6662(a) for 1989 through 1991. We hold that it is. (7) Whether Toraya is liable for an addition to tax for substantial underpayment of tax under section 6661 for 1988. We hold that it is. (8) Alternatively, if the Court determines that Toraya had unreported income from unreported sales, whether it is entitled to theft loss deductions for 1988 through 1991. We hold that it is not. 6 Respondent conceded on opening brief that Toraya is not liable for a late filing addition under sec. 6651(a)(1) for 1989.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011