Anargyros George Mylonas - Page 2

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                                        Additions to Tax         Penalty              
                                        Sec.                       Sec.               
              Year      Deficiency   6651(a)(1)    Sec. 6654     6662(a)              
              1992        $19,240     $4,810.25        --         $3,848              
              1993        58,255      14,564.00    $2,440.84        --                
          After concessions, the only issue remaining for decision is                 
          whether petitioner is liable for the addition to tax authorized             
          by section 6651(a)(1)1 for the taxable year 1993 in the amount of           
          $13,292.2  We hold that he is.                                              
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
               Petitioner Anargyros George Mylonas resided in Houston,                
          Texas, at the time he filed his petition.  At all times relevant,           
          petitioner owned and operated a nightclub (club) which he                   
          reported for tax purposes as a Schedule C business.                         
               During 1993 and 1994, petitioner worked long and demanding             
          hours at his club.  In addition to operating his club, petitioner           
          was renovating it, performing at least some of the work himself.            
          Working at the club or renovating it occupied most of                       
          petitioner's time during 1993 and 1994.                                     

               1All section references are to the Internal Revenue Code in            
          effect for the years in issue.  All Rule references are to the              
          Tax Court Rules of Practice and Procedure.                                  
               2In a stipulation of agreed adjustments, the parties have              
          stipulated revised tax deficiencies for the taxable years 1992              
          and 1993 and the amount of the addition to tax under sec.                   
          6651(a)(1) which is at issue for 1993.                                      

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