Frank and Virginia Muhich - Page 3




                                        - 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