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Addition to Tax and Penalties, I.R.C.
Sec. Sec.
Year Deficiency 6651(a)(1) 6662(h)
1993 $178,093 $10,734 $71,237
1994 192,586 –- 77,034
Respondent, in the alternative, determined a negligence penalty
under section 6662(c). Unless otherwise indicated, all section
references are to the Internal Revenue Code in effect for the
years in issue, and all Rule references are to the Tax Court
Rules of Practice and Procedure.
The issues for decision are whether petitioner is entitled
to certain noncash charitable contribution deductions in excess
of the amounts allowed by respondent, whether petitioner is
liable for an addition to tax for failure to file timely his 1993
Federal income tax return, and whether petitioner is liable for
penalties for gross valuation misstatements on his 1993 and 1994
Federal income tax returns.
FINDINGS OF FACT
Some of the facts have been stipulated, and the facts set
forth in the stipulation are incorporated in our findings by this
reference. At the time the petition in this case was filed,
Samuel Jacobson (petitioner) was a resident of New York, New
York. He has been in the baked goods distribution business for
30 years and owns Operative Cake Corporation (Operative Cake).
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