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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 except
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