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Accuracy-Related Penalty
Year Deficiency Sec. 6662(a)1
1994 $9,048 $1,810
1995 5,650 1,130
We must decide whether the determinations in the notices of
deficiency (notices) that have not been conceded by respondent
should be sustained. We hold that they should.2
Some of the facts have been stipulated and are so found.3
Petitioners Aladar Stolmar (Mr. Stolmar) and Ilona G.
Stolmar, now deceased, resided in Canonsburg, Pennsylvania, at
the time the petitions in these cases were filed.
Respondent determined in the notices, inter alia, that all
of the expenses which petitioners claimed in Schedules C of the
Federal income return (return) that they filed for each of the
years 1994 and 1995 "have been disallowed due to your failure to
1 All section references are to the Internal Revenue Code
in effect for the years at issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
2 Respondent issued a notice of deficiency to Aladar
Stolmar and Ilona G. Stolmar for each of the years 1994 and 1995.
They both filed a petition with respect to each of those notices.
There-after, Ilona G. Stolmar died, and the Court granted
respondent's motion to dismiss these cases for lack of
prosecution as to Ilona G. Stolmar, deceased. Pursuant to this
Opinion and the Court's Order dated Sept. 25, 1998, decisions
will be entered under Rule 155 as to each petitioner in the same
amounts for 1994 and 1995.
3 Respondent objected to certain of the stipulations of
fact on grounds of relevancy, and petitioner Aladar Stolmar
objected to certain other stipulations of fact on relevancy
grounds. We shall give the stipulations of fact whatever weight
we deem ap-propriate in deciding these cases.
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Last modified: May 25, 2011