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the revenue agent erred in computing the amount of sales of
alcoholic beverages sold at discounted prices during "happy hours".
The other remaining issues are (1) whether petitioners are
entitled to deduct 1991 unreimbursed automobile expenses allegedly
incurred in connection with Classic Pub's operation, and (2)
whether petitioners are liable for the section 6662(a) accuracy-
related penalty for 1991, 1992, and 1993.
All section references are to the Internal Revenue Code in
effect for the years under consideration. All Rule references are
to the Tax Court Rules of Practice and Procedure. All dollar
amounts are rounded.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The
stipulation of facts and the attached exhibits are incorporated
herein by this reference.
Background
At the time Michael F. and Jody D. Lambaiso (petitioners),
husband and wife, filed their petition, they resided in Virginia
Beach, Virginia. They filed joint Federal income tax returns for
all years in issue.
Classic Pub
Classic Pub, Inc. is a Virginia corporation. In 1990, it
elected S corporation status for Federal tax purposes;
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Last modified: May 25, 2011