- 2 - 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.Page: Previous 1 2 3 4 Next
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