- 3 - 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;Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011