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Respondent determined a deficiency in petitioners' 1993
Federal income tax in the amount of $2,380, an addition to tax
under section 6651(a) in the amount of $187.15, and an accuracy-
related penalty under section 6662 in the amount of $476.
The issues are: (1) Whether petitioners are entitled to
claim a theft loss; (2) whether petitioners are liable for the
addition to tax under section 6651(a)(1); and (3) whether
petitioners are liable for the accuracy-related penalty under
section 6662(a).
Some of the facts have been stipulated and are so found.
Petitioners resided in Ogden, Utah, at the time the petition was
filed.
Petitioner Michael Richardson (petitioner) filed a Schedule
C with his 1993 Federal income tax return. On the Schedule C, he
listed his business as mining with a business name of Shoe String
Mining. No income or expenses were listed except for $8,500 of
"other" expenses which resulted in a loss in that amount. On the
Schedule C, petitioner stated that the $8,500 was "stolen
equipment not covered by insurance" and listed:
955 Catapiller [sic] Track Loader 5000
35 KW Diesel Gen. 3000
Water Pump 500
In the notice of deficiency, respondent disallowed the
$8,500 claimed loss.
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Last modified: May 25, 2011