- 3 - 3. Whether section 162 allows Midwest to deduct payments to a trust promoter in the amounts of $12,000 and $5,500 for 1994 and 1996, respectively. We hold it does not. 4. Whether section 162 allows Midwest to deduct payments to the trusts in the amounts of $60,000, $103,238, and $132,766 for 1994, 1995, and 1996, respectively. We hold it does. 5. Whether the Muhichs are liable for accuracy-related penalties under section 6662(a) and (b)(1) for 1994 and 1995. We hold they are. 6. Whether Midwest is liable for accuracy-related penalties under section 6662(a) and (b)(2) for 1994, 1995, and 1996. We hold it is to the extent discussed herein. 7. Whether the Muhichs are liable for a penalty under section 6673(a)(1). We hold they are not.2 FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulated facts and exhibits submitted therewith are incorporated herein by this reference. The Muhichs resided in Mahomet, Illinois, when they petitioned the Court. Midwest had its principal place of business in Mahomet, Illinois, when it petitioned the Court. 2 Rule references are to the Tax Court Rules of Practice and Procedure. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the years at issue.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011