jSamuel Jacobson - Page 2




                                        - 2 -                                         
          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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