- 2 - Pursuant to separate notices of deficiency, respondent determined the following deficiencies and accuracy-related penalties: Richard C. and Hattie M. Martin, Docket No. 18241-97: Year Deficiency Sec. 6662(a) 1992 $103,871 $20,774 1993 55,302 11,060 1994 35,991 7,198 William L. and Sylvia L. Martin, Docket No. 18247-97: Year Deficiency Sec. 6662(a) 1992 $62,427 $12,485 1993 21,793 4,359 1994 31,405 6,281 Following concessions by the parties, the primary remaining issue to be resolved is whether Cola Performance Products, Inc. is to be recognized as a distinct taxable entity during 1992, 1993, and 1994, the consequence being the disallowance of certain business losses individually claimed by petitioners for each of those years.1 Also at issue is whether petitioners are liable for section 6662(a) accuracy-related penalties. 1 William L. Martin acknowledged that he was not involved in the automotive crankshaft manufacturing business at issue, and therefore he and his wife concede that they are not entitled to the business losses they individually claimed. They request that all business losses for the years in issue be attributed to Richard C. and Hattie M. Martin.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011