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Respondent determined the following deficiencies and
penalties with regard to petitioners' Federal income taxes:
Penalty
Year Deficiency Sec. 6662(a)
1993 $5,210 $1,042
1994 4,145 829
1995 490 98
After concessions by respondent,2 the issues remaining for
decision are: (1) Whether petitioners received unreported
taxable income in the amounts of $15,687 and $18,7143 for 1993
and 1994, respectively, as shown by unexplained bank deposits
made by them during those years; and (2) whether petitioners are
liable for an accuracy-related penalty for each of the 1993 and
1994 taxable years, pursuant to section 6662(a).
Some of the facts have been stipulated, and they are so
found. The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time of filing the
petition, petitioners resided in New Market, Virginia.
2
Respondent concedes the deficiency in tax and penalty
determined for the 1995 tax year. Additional concessions are
enumerated infra note 3.
3
Respondent's determination that petitioners received
unreported taxable income is reflected as adjustments to
petitioners' Schedule C gross receipts for the tax years in
issue. The amounts set forth above reflect concessions made by
respondent (a reduction in gross receipts for 1993 and 1994 in
the amounts of $450 and $4,904, respectively).
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