J. David Golub - Page 2




                                        - 2 -                                          

                                  Penalties     Addition to Tax                       
               Year      Deficiency     Sec. 6662(a)    Sec. 6651(a)(1)                
               1991      $112,652       $22,530         $5,125                         
               1992      1,746          349            -0-                             
               Respondent subsequently conceded that petitioner is not                 
          liable for the addition to tax under section 6651(a)(1).                     
               Unless otherwise indicated, all section references are to               
          the Internal Revenue Code in effect for the taxable years in                 
          issue.  All Rule references are to the Tax Court Rules of                    
          Practice and Procedure.                                                      
               The issues for decision are:  (1) Whether petitioner failed             
          to report interest income, taxable dividends, and capital gains              
          from the sale of securities on his 1991 Federal income tax                   
          return; (2) whether a State tax refund and credit to petitioner              
          in 1991 are subject to Federal income tax; (3) whether petitioner            
          properly claimed Schedule C deductions on his 1991 and 1992                  
          Federal income tax returns; (4) whether petitioner is permitted              
          to carry over net operating losses to compute his 1991 and 1992              
          Federal income tax liabilities; (5) whether alleged procedural               
          errors by respondent affect petitioner’s liability for the                   
          deficiencies and penalties at issue; (6) whether petitioner is               
          liable for accuracy-related penalties under section 6662(a) for              
          1991 and 1992; and (7) whether petitioner is liable for a penalty            
          under section 6673.                                                          







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Last modified: May 25, 2011