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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.
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Last modified: May 25, 2011