- 2 - Addition to Tax Penalty Year Deficiency Sec. 6651(a)(1) Sec. 6662(a) 1989 $1,363,638 $340,560 $272,728 1990 303,274 -- 60,655 1991 237,234 60,864 47,447 The issues in this case, Iranian bad debt and domestic issues, have been bifurcated for separate resolution. This opinion addresses the domestic issues. After concessions by the parties,2 the sole issue for decision is whether certain payments received by petitioners pursuant to a sale agreement for the sale of real property should be included in gross income in the year received. This issue was submitted by the parties fully stipulated. This reference incorporates herein the stipulation of facts and attached exhibits. At the time they filed their petition, petitioners resided in Huntington Beach, California. FINDINGS OF FACT Sale Agreement On November 1, 1989, Doris and Ferydoun Ahadpour as sellers entered into an “Agreement for Purchase and Sale of Real Property and Escrow Instructions” (Agreement) with buyer Coultrup 2 The parties filed a Stipulation of Settled Issues with this Court on Apr. 17, 1998, resolving all domestic issues except for the issue before this Court. Furthermore, the parties agree that additions to tax under sec. 6651(a)(1) and accuracy-related penalties under sec. 6662(a) shall not apply to the domestic issues for all years at issue.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011