- 2 - penalties under section 6662(a) on petitioners' Federal income tax (tax), as follows: Taxable Accuracy- Year Ended Deficiency Addition to Tax Related Penalty February 28, 1991 $133,316 $50,286 $40,228 February 29, 1992 59,808 5,981 11,962 February 28, 1994 158,230 39,558 31,646 The issues remaining for decision are: (1) Are petitioners entitled to nonrecognition treatment under section 1031 with respect to certain gains realized by petitioner Orlando Industrial Properties, Inc. (OIP) during the taxable year ended February 28, 1991, as a result of the disposi- tion of certain real estate interests? We hold that they are not. (2) Are petitioners entitled to nonrecognition treatment under section 1033 with respect to certain gain realized by OIP during the taxable year ended February 28, 1991, as a result of the condemnation of certain real property? We hold that they are not. (3) Are petitioners liable for the addition to tax under section 6651(a)(1) for each of the taxable years at issue exceptPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011