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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.
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